SONY

Privacy Policy for [Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products)]

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.

SUMMARY OF KEY POINTS

  • Sony uses the Collected Data to provide the Account. Please read Section 1. What personal data does Sony collect in connection with the Account and Section 2. How Sony uses the Collected Data to learn more about this.
  • Depending on where you are located, you have certain rights, which may include a right to object to some of the processing which Sony carries out. Please read Section 8. Privacy Rights to learn more about this.
  • We disclose the Collected Data when we engage Sony group companies or a third party to process data on our behalf, when such sharing is required by law or in certain other situations. Please read Section 3. Who else has access to the Collected Data to learn more about this.
  • Depending on where you are located, the Collected Data may be transferred out of your home country/region to the United States, Japan, and other jurisdictions that may not provide the same level of data protection as your home country/region. Please read Section 5. International Transfer of Collected Data to learn more about this.

1. What personal data does Sony collect in connection with the Account

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:

  • Name
  • Email address;
  • Password;
  • Date of birth;
  • Country/Region; and
  • Language preferences.

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.

2. How Sony uses Collected Data

(A) Providing services

Sony processes Collected Data in order to perform its contract with you to:

  • Create, maintain and control your Account;
  • Linking your TV, mobile or application ("Device”) and the Account; and
  • Respond to your inquiry about the Account.

(B) Email Marketing

Sony will 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 Electronics Inc or Sony of Canada Ltd depending on where you are located.

With your consent, Sony Electronics Inc or Sony of Canada Ltd will provide you with information, recommendations and advertisements, and marketing regarding Sony group companies’ products, services and other offerings that may be of interest to you via email.


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 Electronics Inc or Sony of Canada Ltd depending on where you are located.


For more information on the processing of personal information by Sony Electronics Inc and Sony of Canada Ltd, please see the privacy policies below.


Sony Electronics Inc.

https://products.sel.sony.com/SEL/legal/privacy.html [Privacy Policy] and CA Privacy Notice


Sony of Canada Ltd.

(EN) http://corporate.sony.ca/view/privacy.htm

(FR) http://fr.corporate.sony.ca/view/politiquedeconfidentialite.htm

3. Who else has access to Collected Data?

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 Electronics Inc or Sony of Canada Ltd.


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.

4. Data Retention, Managing Collected Data

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.

5. International Transfer of 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.

6. Security

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.

7. Children’s privacy

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.

8. Privacy Rights

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.


[Notice to US Residents/California Residents]


(i) Notice to Residents of Colorado, Connecticut, Utah, and Virginia


We set forth in our Privacy Policy and Table 1 below 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:


Right to Know: the right to confirm whether we are processing personal data about you.


Right to Correct: the right to correct inaccurate Personal Data we hold about you.


Right to Delete: the right to delete the Personal Data provided by you or obtained about you.


Right to Data Portability: the right to access your personal data and obtain a copy of the Personal Data previously collected by us and, to the extent feasible, in a readily usable format to allow data portability.


Right to Appeal: If for any reason you would like to appeal a decision made by us relating to your request to exercise privacy rights, you have the right to submit an appeal to us. Please include your full name, the basis for your appeal, and any additional information to consider.


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


Right to Opt-Out of Targeted Advertising: Your local Sony electronics company may engage in online advertising and analytics practices that may be considered “targeted advertising” or a “sale” of data under applicable state law.


To exercise your rights to opt-out targeted advertising, please ensure that the setting for “Personal Information” in the [Account Setting] on the account page of Account accessible from the applicable app or service is disabled.

You may also submit a request here: Opt-out of Targeting Advertising


Right to Opt-Out of Profiling or Sale of Personal Information: While state laws may permit you to opt-out of the sale of your Personal Data and out of profiling in furtherance of decisions that produce legal or similarly significant effects, we do not engage in either of these activities at this time.


(ii) Notice to California residents: California Privacy Notice


This California Privacy Notice is effective as of 7/10/2024.


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, as amended, 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:

  • Right to Know. Request information regarding what Personal Information we collect, use, disclose, and sell, including the right to request that we provide you with the categories and /or specific pieces of Personal Information we have collected about you;
  • Right to Delete. Request deletion of the Personal Information we collect about you;
  • Right to Correct. Request correction of inaccurate Personal Information that we maintain about you;
  • "Do Not Sell or Share My Personal Information." Request to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising). As we do not knowingly collect Personal Information of residents younger than the age of 16, we also do not knowingly sell or share for cross-contextual behavioral advertising their Personal Information.
  • "Limit the Use and Disclosure of Sensitive Personal Information." A business must provide the Right to Limit the Use and Disclosure of Sensitive Personal Information only when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or does not fall under certain statutory exceptions. Our use of any Sensitive Personal Information falls within an exception, so we do not offer this right at this time.

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 authorizing 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 description 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 confirm 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 representative. 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.


Do Not Sell or Share for Cross Context Behavioral Advertising

Right to Opt-Out of Sale/Sharing

To opt-out of the “sale” or sharing of your personal information for cross-contextual behavioral advertising, please ensure that the setting for “Personal Information” in the [Account Setting] on the account page of Account accessible from the applicable app or service is disabled, and submit a request at: Do Not Sell/Share My Personal Information


You may also submit a request here: Opt-out of Targeting Advertising


Data Retention. Sony retains data for as long as you hold the Account. Sony either deletes Collected Data or de-identifies the data it holds after approximately six (6) months from the deletion of such Account, except as required or permitted by law.


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 reasonably 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.


Personal Information We Collect & Purposes for Collection

The Personal Information we collect about you will depend upon how you use the Account. 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 consent is required by applicable law.


We may have used Personal Information 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: Email address; your name, postal code, online identifier such as IP address; Device ID, Android

  • Provide account service
  • Providing “Help” upon your request
  • To provide you with information and advertisements
  • Compliance with law
  • Exercising legal rights
  • Sony group companies
  • IT Service Providers
  • Hosting Service Providers
  • Customer service providers
Third party ad vendors via our local operating company

Electronics and Network Information:


Such as: usage status

  • To provide Account services
  • Compliance with law
  • Exercising legal rights
  • Sony group companies
  • IT Service Providers
  • Hosting Service Providers
  • Customer service providers
None

Sensitive Information


Such as: your log-in/password information

  • To provide the account service
  • Sony group companies
  • IT Service Providers
  • Hosting Service Providers
None

Inferences Drawn from Other Information and Consumer Characteristics:


These may relate to demographics (e.g., gender, age, region/general location), interests or hobbies, and inferences drawn from collected information.

  • Providing features and functions of the Account
  • To provide you with information and advertisements
  • Compliance with law
  • Exercising legal rights
  • Sony group companies
  • IT Service Providers
  • Hosting Service Providers
Third party ad vendors via our local operating company

For more information about our local Sony electronics company’s California privacy practices, please refer to this California-specific information here: Calif. Privacy Notice


Additional Notice to California Residents:


If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to which we may have disclosed, within the past year, personal information pertaining to you and your family for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to privacy@am.sony.com, and include your name, email address, mailing address or zip code, and a reference to “Your California Privacy Rights – Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products).” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.


(iii) Notice to Nevada Residents:

If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. Sony does not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if Sony were to engage in such a sale in the future, you may submit your request in writing to: privacy@am.sony.com. Your request must reference “Your Nevada Rights – Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products)” and include your name, mailing address, zip code, and email address. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. We will respond to valid requests within 60 days.


[Notice to Quebec (Canada) Residents]

This notice sets forth disclosures and rights for consumers residing in Québec regarding their personal information, as required by the Québec’s Data Privacy Law 25.


Profiling: With your consent, we may use technologies which collect information about your use of the application associated with your Account that may enable us to develop a profile of your interests or preferences.


Location Tracking: We may use technologies which collect information about your general location, such as the country in which you are located; however, we do not track your location without your consent.


Consumer Rights:

Subject to certain exceptions, you may have the following rights regarding your personal information:

  • Right to Access and Request Information On Data Processing. Request information about our data processing activities, namely what personal information was collected from you and how we process it. You may ask us to clarify the categories of persons that have access to your personal information and the applicable retention period for that information.
  • Right to Rectify. Request rectification of inaccurate personal information we maintain about you.
  • Rights Regarding the Use of Automated Decision-making. You have the right to request that we tell you if we use your personal information to render a decision based exclusively on automated processing of such information and additional information about such processing. However, Sony does not use personal information to render any decisions based exclusively on an automated processing of such information.
  • Right to Withdraw Consent. Withdraw that your consent to our collection, use, and disclosure of personal information at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights: If you are a Quebec resident and wish to exercise your right(s), please: submit your request here: SOCAN Privacy Request Webform; or you may call us at: 1-888-494-7669.

For requests to access, in order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.


Contact Information for Sony Canada’s Privacy Officer is available in Section 10. Contact Information.

9. Changes

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.

10. Contact Information

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:

The US and Canada: privacy@am.sony.com