1. SUMMARY OF KEY POINTS

• We use the Collected Data (defined below) for providing you with features and functions of Auto Play and improving/developing SONY’s products and services. Please read Section 2. What information does SONY collect? and Section 3. How does SONY use the Collected Data? to learn more.
• We will share or disclose the Collected Data when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Please read Section 4. Who else has access to the Collected Data? to learn more.

2. What information does SONY collect?

SONY collects and uses information or data as described below. Some of this information may be considered personal information under applicable law in your jurisdiction, and it is collected when you choose to provide information to us or automatically when you use Auto Play (collectively, the “Collected Data”).

(i) Information about your device on which Auto Play is installed (the “Installed Device”) and component parts thereof:

• Device ID which is to be allocated automatically and specifications/features (e.g. product type, manufacturer name, and model name);
• OS and OS version
• Language code, country or region, time zone;
• Operational status of your Installed Device and component parts thereof (e.g. sensors, display); and
• IP address used by such Installed Device’s internet connection.

(ii) Information about Auto Play:

• Application ID (assigned to Auto Play by us; it is not a unique identifier which would allow us to identify a specific user);
• Application version;
• Time stamp related to the usage of Auto Play on the Installed Device;
• Information regarding your operation and usage of Auto Play on the Installed Device, including total time for your operation and usage, signals that trigger the start of playing music and execution history of other support functions such as switching playlist, audio notifications and text-to speech feature while SONY will not collect or access the contents of the music you listen to, your playlist, audio notifications or the text-to speech. Call starting time and ending time logs relating to your usage of Related Device may be used to generate signals, while SONY will not collect or access information about call destination or the content of calls. Your linked application calendar settings (i.e availability) will be also used as such signals, while SONY will not collect or access the content of your schedule or calendar.
• Information regarding settings and usage of your linked audio applications (QQMusic, Apple Music ,Endel etc, while SONY will not collect or access the contents of your music you listen to); and
• Information about your environment collected in questionnaires.

(iii) Information about your headphone product(s) connected to the Installed Device and detected, or registered to Auto Play (“Related Device”):

• Device IDs (such as, Bluetooth address and the identifier which is to be automatically allocated at the time of registration) and specifications/features (e.g. product type, device name, manufacturer name, and model name).
  The Related Device will also be detected if it is connected to an Installed Device while Auto Play is not running. If a detected related device is not one registered with Auto Play, no further processing will occur.

3. How does SONY use the Collected Data?

SONY uses the Collected Data to provide you the features and functions of Auto Play and the related services, to answer your inquiries and to provide requested service. Please note that your consent forms the legal basis for SONY processing Collected Data for such provisions.In addition, SONY uses your Collected Data for the following purposes:

(i) Improving/developing SONY´s products and services

SONY uses the Collected Data to improve and develop SONY’s current and future products and services, and it will be linked and analyzed in conjunction with the data we collect through other SONY audio applications if you use one of those. For the collected data through those applications, please refer to the privacy policies for those applications or services.

Product improvement and/or development includes those activities relating to either an improvement of the technical functions of Auto Play and/or the Related Device or the usability of such product(s) for the user´s convenience.

Please note that your consent forms the legal basis for SONY processing Collected Data for improving/developing SONY’s products and services. Where you select “Agree” on “Product and service improvement” section of the privacy setting, then we process the Collected Data because you have given us your consent.

(ii) Marketing strategies and forecasting

SONY uses the Collected Data for marketing strategies and forecasting, but not for marketing communications. The Collected Data will be linked and analyzed in conjunction with the data we collect through other SONY audio applications if you use one of those. For the collected data through those applications, please refer to the privacy policies for those applications or services.

Please note that your consent forms the legal basis for SONY processing Collected Data for marketing strategies and forecasting. Where you select “Agree and Proceed” to this Privacy Policy, then we process the Collected Data because you have given us your consent.

(iii) Compliance with Law

SONY Processes the Collected Data in order to comply with applicable law and regulations including a) responding to requests from government or public authorities, law enforcement officials, courts or regulators conducting an investigation and b) to enforce compliance with our terms of use and other policies and to help other organizations (such as copyright owners) to enforce their rights in accordance with our legal and regulatory obligations under applicable laws.

Please note that the legal basis for SONY processing Collected Data for the purpose of complying with applicable law and regulations is SONY’S legal obligation.

4. Who else has access to the Collected Data?

We do not share personal information with unaffiliated third parties for their own marketing purposes but we will share aggregate data and de-identified data with third parties. In addition, SONY will share Collected Data with SONY Affiliates and third parties as follows:

SONY Affiliates

The Collected Data will be shared at aggregate level with and used by SONY Affiliates for internal business purposes such as marketing strategies and forecasting and for product and service improvement and development, and it may be linked and analyzed in conjunction with the data we collect through other Sony audio applications if you use one of those.
SONY will otherwise share Collected Data with SONY Affiliates for other purposes set out in this Privacy Policy.
If you contact your local SONY Affiliate in relation to queries about Auto Play, or for repair or return requests of Related Devices we will also need to share Collected Data with that SONY Affiliate in connection with that request.

Service Providers

SONY and SONY Affiliates will use third party service providers to process the Collected Data on their behalf for the purposes set out in this Privacy Policy (these are IT service providers and data hosting providers). Our hosting provider is Amazon Web Services in the US, acting as our entrusted processor.

Business transfer

In the event that SONY or a SONY Affiliate sells or transfers a portion or all of its business, the Collected Data will be transferred by SONY or such SONY Affiliate to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer.

Government Authorities/ Law Enforcement Officials/Regulators or courts

Collected Data will be disclosed to government authorities, law enforcement officials, regulators or courts for the purposes outlined in Section 3 above.

Other Unaffiliated Third Parties

We will disclose Collected Data to auditors or similar external consultants like lawyers or tax advisors, to defend and exercise our legal rights (e.g. enforcing compliance with the terms of use) and as we believe necessary to comply with our legal obligations.

5. Data Retention

SONY will keep the Collected Data for as long as it is necessary for the relationship with you and the purposes detailed in Section 3 or otherwise permitted or required under applicable law.

SONY will retain Collected Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Collected Data for specific periods.

With regard to Collected Data which is processed based on your consent declaration, SONY will apply a maximum of twenty-seven (27) months retention period from the date of the collection of the Collected Data.

If you have any questions about SONY’s data retention practices please contact SONY at www.sony.net/SonyInfo/Support/.

6. Location of data storage and processing

The Collected Data may be processed and stored on our servers in Amazon Web Services’ data centers in the United States. As described in “4. Who else has access to the Collected Data?” above, the operator of Amazon Web Services is the IT service provider and data hosting provider who acts as our entrusted processor and processes the Collected Data in accordance with our instructions. Some of the third parties described in “4. Who else has access to the Collected Data?” with whom we share the Collected Data may be located in countries or regions other than China and the United States. Please contact us as indicated in “11. Contact Us” below if you want to know further details of any such third party.

7. Security

SONY undertakes reasonable security measures designed to protect against the loss, misuse or alteration of the Collected Data. Although SONY strives to protect the Collected Data, SONY cannot guarantee or warrant the security of any Collected Data transmitted to SONY through Auto Play or that SONY stores on its systems or that is stored on SONY’s third party contractors' systems.

8. Children’s privacy

SONY is committed to complying with all applicable laws and regulations regarding the collection, storage and use of the Collected Data concerning children, including the Children's Online Privacy Protection Act in the United States.

Auto Play is intended for a general audience; Auto Play is not directed to and does not knowingly collect personal information from children younger than age of 14. Depending on your country/region of residence, this threshold age for a child may differ.

If you are a parent or guardian and are concerned that your child has provided SONY with personal information (as defined by applicable law), you should contact us as indicated in Section 11 “Contact us” below.

9. Changes/Policy Governs Use

SONY reserves the right to make changes to this Privacy Policy and will notify you of any changes by prominently posting notice of the amendment on or within Auto Play. We may also provide notice to you in other ways, such as through contact information you have provided. You are advised to consult the posted Privacy Policy regularly for any changes.

10. Privacy Rights

You have certain rights with respect to the Collected Data SONY holds about you. These may include the right to request a copy of the Collected Data that SONY holds about you and/or you may request that SONY corrects or supplements such Collected Data if it is inaccurate. You may also ask us to provide some types of the Collected Data to you, or another organization nominated by you, in a structured and machine-readable format. Where the processing of any Collected Data is based on your consent, you may withdraw the consent and request SONY to suspend or terminate the relevant processing. In addition, if you would like to exercise any of these rights, please contact us as indicated in “11. Contact Us” below.

If you are not satisfied with how we have handled your questions, concerns or have any complaints about how we process personal data, you have a right to lodge a complaint with the departments fulfilling personal information protection duties and responsibilities.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at SChina_Privacy_Dep@sony.com.

If you wish to exercise any legal right you may have in respect of the Collected Data, please contact us as below:

Service Line : 400 810 9000

Service Period : 9:00-18:00 (Monday - Sunday)

Email : ccc@sony.com.cn