SONY

PRIVACY POLICY FOR “Sony | Auto Play” APPLICATION

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.

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.

1. SUMMARY OF KEY POINTS

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, 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. Auto Play will access location data in your Installed Device. Such location data is used 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. 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 further details on Google Maps SDK, please see Section 4. Who else has access to the Collected Data.
  • Information regarding settings and usage of your linked audio applications (Endel, Spotify, Apple Music 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. 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.

(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.

(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.

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 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.

Google services

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: 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

5. Data Retention

SONY will start processing the data after you provide us with or allow us to collect your data or a third party's data through various methods.

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. Transfer of the Collected Data internationally and Consent to processing

The Collected Data may be processed, stored and transferred from your country/regions of residence to countries/regions outside your country/region of residence, including in particular Japan and the United States. By using the Application, 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. We use a variety of legal mechanisms, including data sharing agreements, to ensure adequate level of protection of your Collected Data.

This may impact your rights in your local jurisdiction and also in the applicable overseas jurisdiction(s). These overseas jurisdictions may also need to disclose your personal information to a third party, such as an overseas authority.

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 or about children younger than age of 18 without the consent of a parent or guardian. If you are under the age of 18, please ensure that you have your parents’ or guardian’s consent to this Policy and to your use of Auto Play. 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

In some countries/regions, you have certain rights with respect to the Collected Data that SONY or a SONY Affiliate holds about you. You may have the right to access such Collected Data; restrict the usage of such Collected Data; object to or withdraw consent for processing of such Collected Data; rectify such Collected Data where inaccurate or incomplete; request for deletion of such Collected Data, including anonymization of the Collected Data; and/or request us to provide a copy of such Collected Data to you, or another organization nominated by you, in a structured and machine-readable format. If you would like to exercise any of these rights, please contact SONY at www.sony.net/SonyInfo/Support/. 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 local data protection supervisory authority.

11. Additional Notice

[For Residents in Asia & Oceania regions]

Please read this Privacy Policy carefully because by using Auto Play, you will be deemed to have agreed and consented to the terms of this Privacy Policy.

By agreeing to this Privacy Policy and by using the Auto Play you agree that you will not hold SONY or SONY Affiliates liable to any complaints or damages whatsoever relating to the processing of the Collected Data by an acquiring entity in the event a business transfer as described in Section 4. of this Privacy Policy takes place.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have in respect of the Collected Data, please contact us at www.sony.net/SonyInfo/Support/

FOR RESIDENTS IN KOREA

Sony Corporation, would designate a domestic representation according to Korea local regulation as following.

Name: Sony Korea Corporation (representative director:Okura Kikuo)

Address: 24F, One IFC, 10 Gukjegeumyung-Ro, Yeongdeungpo-Gu, Seoul, Korea

Contact information: 02-1588-0911/sokprivacy@sony.co.kr

FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:

If you have any concerns about how we process your data, you can find our contact details below or on the website of your local Sony Group Companies at:

For Mexico, Central and South America and the Caribbean:

Regional Latin America Privacy Office at https://www.sony.com/locale-selector

Africa and Middle East: https://www.sony-mea.com/en/locale-selector

Asia & Oceania: http://www.sony-asia.com/countryselector.html