Effective Date: This Privacy Policy was revised and is effective as of October 24, 2023.
This Privacy Policy applies to the “Sony | Auto Play” application (“Auto Play”). This Privacy Policy explains our collection, use, sharing and other practices regarding your data when you use Auto Play.
Auto Play is a mobile application dedicated to wireless headphones from SONY, which can access the schedule and other notices on your mobile device and start playing music from a linked application in a timely manner.
In this Privacy Policy, we use “SONY,” "we," "us," and "our" to refer to Sony Corporation. “SONY Affiliates” shall mean Sony Group Corporation, which is the ultimate parent company of SONY and any legal entities controlled by Sony Group Corporation. The term “control” in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity.
For the purposes of applicable data protection laws and regulations where the concepts of "controller" and “processor” are defined, SONY is the "controller" of the Collected Data described in this Privacy Policy.
This Privacy Policy only applies to Auto Play and is in addition to any other privacy policy that may apply to your interactions with SONY and SONY Affiliates or any third party, regarding their product, software or service.
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”).
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. In addition, SONY uses your Collected Data for the following purposes:
SONY uses the Collected Data to improve and develop SONY’s current and future products and services, 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. 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.
SONY uses the Collected Data for marketing strategies and forecasting, but not for marketing communications. The Collected Data may 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.
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 offi-cials, 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.
We do not share personal information with unaffiliated third parties for their own marketing purposes but we may share non-personal information, including aggregate data and de-identified data, with third parties to the fullest extent allowed by law. In addition, SONY may share Collected Data with SONY Affiliates and third parties as follows:
The Collected Data may 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 may otherwise share Collected Data with SONY Affiliates as processor(s) of the data to provide services for the 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 also may need to share Collected Data with that SONY Affiliate in connection with that request.
SONY and SONY Affiliates may 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 processor.
In the event that SONY or a SONY Affiliate sells or transfers a portion or all of its business, the Collected Data may 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.
Collected Data may be disclosed to government authorities, law enforcement officials, regulators or courts for the purposes outlined in Section 3 above.
We may 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.
Firebase Crashlytics: Auto Play uses Firebase Crashlytics, a service provided by Google Inc. (“Google”).Collected Data is shared with Google to analyze the crash reports and fix Auto Play’s stability issues. For further information on Firebase Crashlytics, visit: Firebase Crashlytics | A powerful Android and iOS crash reporting solution (google.com)
To better understand how Google uses the information it receives, visit: https://policies.google.com/privacy.
Google Maps SDK: Auto Play may access location data in your Installed Device. It uses Google Maps SDK to generate signals for when you start or stop moving, which will trigger the start of music playing at appropriate times. For clarity, SONY will not collect or access location data . To better understand how Google uses the information it receives, visit:https://policies.google.com/privacy. Please also see terms of service for the details on Google Maps SDK :https://maps.google.com/help/terms_maps.html
For users in the United States, Auto Play also uses Google Maps SDK to share location data when you enable the weather function of Auto Play. For clarity, Sony does not collect such loca-tion data and the location data is sent directly to the National Weather Service.
SONY will delete or de-identify the Collected Data after approximately 27 months from the time of collection of each data, except as required or permitted under applicable law.
SONY may 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.
The Collected Data may be processed, stored and transferred to countries/regions outside your country/region of residence, including in particular the United States and Japan. By using Auto Play, or providing us with any information, you fully understand and consent to this transfer, processing and storage of your information in the United States, Japan and other jurisdictions, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. Further, courts, law enforcement, and other authorities in countries/regions outside your residence may be entitled to access Collected Data upon its transfer.
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.
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 16. Depending on your coun-try/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 below in Section 11 “Contact Us”.
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.
Your continued use of Auto Play after the posted effective date will constitute acceptance of, and agreement to be bound by those changes to the extent allowed by law.
In some countries, you have certain rights with respect to the Collected Data Sony processes 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, correct, delete, block/restrict processing of such Collected Data. In some countries, you may also ask us to provide your Collected Data to you in a structured, machine-readable format and ask us to share (port) such data with another organisation. These rights may be limited, for example, if fulfilling your request would reveal Collected Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. If you would like to exercise any of these rights, please see the section on State Notices and other Privacy Rights below or contact us as described in Section 11 “Contact Us” below.
If you have any questions or comments about our practices regarding your Collected Data or about this Privacy Policy, please contact us at:
[United States]
Sony Electronics Inc.
115 West Century Rd., Suite 250
Paramus, NJ 07652
Attn: Privacy Office
Telephone: 1-833-681-9900
Email: privacy@am.sony.com
[Canada]
Sony of Canada Ltd.,
2235 Shepard Avenue East, Suite 700 Toronto, ON M2J 5B5
Attn: Privacy Officer, Law Department
Telephone, toll-free (within Canada): 1-888-494-7669
Email:privacy@am.sony.com
We set forth in our Privacy Policy and Table 1 the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
Starting in 2023, consumers in certain states, including Colorado, Connecticut, Utah, and Virginia, may have the following rights:
If you would like to submit a request to exercise one of the rights listed above, you can do so by completing this form: Data Requests
Please refer to Table 1 for more information about the categories of data we collect, the purposes of collection and with whom data may be shared.
This California Privacy Notice is effective as of October 24, 2023.
This California Privacy Notice supplements our Privacy Policy sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Privacy Rights Act and any implementing regulations adopted thereunder (“CPRA”). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.
California Consumer Rights. Subject to certain exceptions, as a California consumer, you may have the following rights regarding your CA Personal Information:
Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authoriz-ing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear de-scription of the permission granted. Alternatively, you may submit a copy of a power of attorney under applicable state law. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly con-firm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized repre-sentative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We will only use the information you provide in a request to verify your identity.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify your identity, we will not be able to process the request.
Exercising Your Rights.
Right to Know; Right to Delete; Right to Correct
If you are a California Consumer and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please submit your request at: Data Requests; or you may call us toll-free at 1-833-681-9900.Data Reporting
Click here to access our data reporting metrics for the previous calendar year.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will not discriminate against you for exercising your CPRA rights.
Notice of Financial Incentive
Under California regulations, if we offer certain loyalty or similar program(s) directly or reason-ably related to the collection, retention or deletion of your Personal Information, such program may be considered a “financial incentive”. In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.
Data Retention
We retain all categories of personal information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice. In particular, we retain your personal information while you have an account with us, or while you are using the Application or continuing to interact with us. We take steps to de-identify or delete data when it is no longer needed.
Personal Information We Collect & Purposes for Collection
The Personal Information we collect about you will depend upon how you use Auto Play or oth-erwise interact with us. Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and con-sent is required by the CPRA.
We may have used Personal Information collected from you, your products and/devices for the business or commercial purposes described in Table 1:
[Table 1]
| Categories of Personal Information Collected | Purposes for Collection of Personal Information | Who We Share Personal Information With for a Business Purpose | Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising |
|---|---|---|---|
Identifiers Such as: Device ID, Application ID, IP address |
|
|
|
Consumer Characteristics Such as: Demographic information including Language; country code; time zone |
|
|
|
Electronic network activity Such as: Application usage logs; operational status; links to other applications and usage |
|
|
Not applicable |
This notice sets forth disclosures and rights for consumers residing in Québec, Canada regarding their personal information, as required by the Québec’s Data Privacy Law 25.
Contact information for Sony’s Privacy Officer:
Sony of Canada Ltd.,
Attn: Privacy Officer, Law Department
2235 Shepard Avenue East, Suite 700 Toronto, ON M2J 5B5
Telephone: 1-888-494-7669 (toll free within Canada)
Email: privacy@am.sony.com
Notice on Automated Decision Making: Sony does not use personal information to render any deci-sions based exclusively on an automated processing of such personal information.
Residents of Québec’s Consumer Rights:
Subject to certain exceptions, you may have the following rights regarding your personal information:
Exercising your rights: If you are a Quebec resident and wish to exercise your Right to Access, Right to Erasure and/or Right to Rectify, please: submit your request here: Data Requests; or you may call us toll-free number 1-833-681-9900.
