Last Updated: 7/10/2024
This Privacy Policy explains how we collect, use and/or store your personal data in connection with your [Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products)] (“Account”). It also describes your data protection rights, including your right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in Section 8. Privacy Rights below.
By “we” “us” or “our”, we mean Sony Corporation (1-7-1, Konan, Minato-ku, Tokyo 108-0075, Japan) (“Sony”), which is a Sony group company. 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.
In order to use certain Sony applications or application features, you will need to maintain this Account.
This privacy policy only applies to this Account service and is in addition to any other privacy policy that may apply to your interactions with the Sony group companies or any third party, regarding their products, software or services.
In this Privacy Policy, when we say:
“Sony group companies”, we mean Sony Group Corporation or the ultimate parent company of Sony and any company or legal entity that is controlled by the ultimate parent company of Sony.
We collect following information in addition to information about your usage of the website of the Account (access status, etc.), some of which may be considered personal information in certain jurisdictions (collectively, the “Collected Data”).
(A) Basic information
When you create the Account, Sony will collect the following:
Please be aware that when you have another Sony account(s) for other Sony group companies’ products and services and you use the same sign-in ID (email address) and password to sign in to this Account, the accounts will be linked automatically and you will be able to sign in to this Account with the same sign-in ID (email address) and password. For more information about linking accounts, please go: https://acm.account.sony.com/linking-account
For password management/reset and authentication, you can also register a security question and answer and cellphone number at the Account security setting page. This Collected Data is not used for any other purpose.
(B) Information related to authentication/authorization
When you use the Account, Sony will use cookies, tokens, and other technologies to collect credentials (information issued to identify customers, such as a combination of random alphanumeric characters) necessary for authentication and authorization with this Account.
(A) Providing services
Sony processes Collected Data in order to perform its contract with you to:
Please note that the legal basis under EU-law for Sony processing your Collected Data is Article 6 (1) (b) General Data Protection Regulation ("GDPR”), the necessary of performance of the [Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products) Terms of Use] we have with you.
(B) Email Marketing
With your consent, Sony will for this purpose collect and share your Collected Data (except for information about your usage of the website of the Account (access status, etc.), tokens issued as a result of sign-in authentication and ID provider service that you choose) with Sony Europe B.V. (as an independent controller) depending on where you are located. With your consent, Sony Europe B.V. will provide you with general information, recommendations and advertisements, and marketing regarding Sony group companies’ products, services and other offerings that may be of interest to you via email.
Your consent forms the legal basis for Sony to share Collected Data with Sony Europe B.V. providing you with email marketing communication as outlined under EU-law (Article 6 (1) (a) GDPR).
Please note that the Collected Data may be combined with usage data from the applicable application or service you use so that this email marketing may be personalized or tailored to provide you new product information, articles, offers, promotions, and recommendations about Sony group companies’ products, services and other offerings that may be of interest to you. With your above consent, Sony will for this purpose share Collected Data as per your preferences (set by you in the respective product app) with Sony Europe B.V. (as an independent controller).
[For EEA residents]
With your additional consent (expressed in a product application and My Sony ID you created) Sony Europe B.V. achieves the personalization or tailoring through profiling of the Collected Data (except for information about your usage of the website of the Account, tokens issued as a result of sign-in authentication and ID provider service that you choose) and other data (such as user log data from the use of the Device) it collected.
Please note that your consent forms the legal basis for Sony to share Collected Data with Sony Europe B.V. providing you with personalized or tailored email marketing communication as outlined under EU-law (Article 6 (1) (a) GDPR).
You can unsubscribe from receiving email marketing any time by using the “unsubscribe” link in the email from Sony Europe B.V. or by referring to its privacy policy. For more information on the privacy practices of Sony group companies, please refer to the respective privacy policy as follows:
https://www.sony.co.uk/eu/pages/privacy/en_GB/privacy_policy.html
Sony will make Collected Data available to third party as below:
Sony group companies
If you contact your Sony group company in relation to queries or for repair or return requests of Sony group companies’ products, we also may need to share Collected Data with that Sony group company in connection with your request.
For the purposes stipulated in section 2(B) Email Marketing, Sony may also make Collected data available to Sony Europe B.V.
Third-party service providers
Sony may use Sony group companies and third party service providers to process the Collected Data. Our service providers include customer support vendors, IT vendors and data hosting vendors, including Amazon Web Services, Inc., which provides data back-up services to us and is located in the US. The service providers are engaged for the purposes of pursuing the activities outlined in this Privacy Policy on Sony’s behalf, acting as processors of Sony.
Business transfer
In the event that we sell or transfer a portion or all of our business, Collected Data may be transferred by us to the purchasing or acquiring entity as part of the transaction. We will continue to ensure the confidentiality of the Collected Data before such transaction occurs, and after such transaction, we will delete the Collected Data as soon as reasonably practicable after such transaction.
Compliance and enforcement
We will retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, Sony group companies or third parties, against illegal, criminal or harmful activities.
We will continue to retain Collected Data for 6 months after you delete the Account unless local law tells us to keep it for longer. Please note that we may be required to retain certain information by law.
Where Sony no longer requires the Collected Data, it will be destroyed or de-identified in line with internal Sony information security policies. When we say de-identified, we mean that we will remove information that could be used to identify you from the Collected Data.
Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy to various jurisdictions outside your jurisdiction of residence, including Japan and the US. Collected Data will be processed by staff operating outside your jurisdiction who work for us or for one of our service providers and may be seen by such staff in those countries.
By providing us with the Collected Data, you consent to the transfer, processing and storage of your information in jurisdictions in which 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. We have taken reasonable steps to ensure that any transfers of Collected Data meet the requirement of applicable data protection legislation and that your personal information will not be used for purposes not relevant to the purpose for which it was collected or communicated to service providers without your consent except when required or permitted by law.
Where Collected Data is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, the Collected Data is adequately protected by EU Commission approved standard contractual clauses which can be accessed here or Binding Corporate Rules.
Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. We take information security very seriously but we cannot guarantee or warrant the absolute security of any information that we store on our systems or that is stored on our third party contractors’ systems.
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries.
This Account is intended for a general audience; it is not directed to and does not knowingly collect personal information from children under the age of 16. 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 us with personal information without your consent, you should contact us as indicated in Section 10. Contact Information below.
In some countries, 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 or Sony group companies holds about you and/or you may request that Sony or the Sony group companies, corrects, amends, deletes, erases, destroys, objects or blocks/restrict processing and/or use of such Collected Data if it is inaccurate. In some countries, you may also ask us to provide some types of the Collected Data to you in a structured, machine-readable format and ask us to share (port) such data with another controller. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete Collected Data 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 contact us as described in Section 10. Contact Information 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 local data protection supervisory authority.
If you are located in the EEA, UK or Switzerland, you may have the following rights (pursuant to Art. 15-18 and Art. 19-21 GDPR, if you are located in the EEA):
These rights may be limited, for example if fulfilling your request would reveal personal 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.
You also have the right to lodge a complaint to a supervisory authority for data protection (Art. 77(1) GDPR) in the country/region where you live, where you work, or where you consider that a breach of data protection has occurred – although we hope that we can assist with queries or concerns you may have about our use of your Collected Data.
From time to time we may have to update this Privacy Policy. We will let you know of any material changes to this Privacy Policy through the Account. If the applicable law requires us to obtain your consent, we will ask you for your consent.
FOR RESIDENTS IN THE EU or Switzerland:
If you have a privacy concern, complaint or question, please contact Sony Europe B.V., who is Sony’s representative in the EU, at privacyoffice.SEU@sony.com
You can also get in touch by writing to Sony Europe B.V., The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at https://sony-europe.com.
FOR RESIDENTS IN THE UK:
If you have a privacy concern, complaint or question please contact Sony Europe B.V., who is Sony’s representative in the UK, at: privacyoffice.SEU@sony.com
You can also get in touch by writing to Sony Europe B.V., The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.
