Last Updated and Effective Date: August 5, 2024
This privacy policy (“Privacy Policy”) applies to the “TV Control with Smart Speakers” Application (the “Application”). The Application is an application to enable a compatible voice-control device to control your TV. In this Privacy Policy, when we say “Sony”, “we”, “us” and “our”, we mean Sony Corporation with an address of 1-7-1 Konan, Minato-ku, Tokyo 108-0075, Japan. Sony acts as data controller (as this term is defined under the General Data Protection Regulation ((EU) 2016/679) or any other applicable local legislation or regulation) and may collect and consolidate certain information about you, this Application and/or your TV. This is explained in detail in this Privacy Policy.
In this Privacy Policy, “Sony group companies” shall mean Sony Group Corporation 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 the Application and is in addition to any other privacy policy that may apply to your interactions with any Sony group company or any third party, regarding their product, software or service.
PLEASE NOTE: In order to use this Application, you will need to set up a Sony account (Sony’s Cloud Service for Home Entertainment & Sound Products) which has a separate privacy policy. The voice-control device that is compatible with your TV will depend upon the TV model.
Sony may receive the following data that you provide and that is collected automatically from your TV or third parties when you use this Application (the “Collected Data”). Some of the Collected Data may be considered personal information under applicable law in your jurisdiction.
The UUID issued by Sony’s cloud service is a unique number assigned to your Application in order to send Voice command from compatible voice-control devices to your BRAVIA. The Access token and Authorization Code for Sony’s cloud service are issued to your Application as a result of the authentication by Sony’s cloud service.
Sony uses the Collected Data to process your request, via a compatible voice-control device, to do things like turning on/off your TV, channel switching, volume control and turning on/off installed application. Upon receiving your request, Sony processes the voice commend for your TV and sends back a response from your TV to your compatible voice control device.
It is necessary for Sony to use this Collected Data to provide you with these services.
Please note that the legal basis under EU law for this processing is Article 6 (1) (b) General Data Protection Regulation, the necessity of performing our obligations in connection with the end user license agreement Sony has with you for your use of the Application.
Sony also processes the Collected Data where it is necessary to ensure information security.
Please note that the legal basis under EU law for this processing is Article 6 (1) (f) General Data Protection Regulation, the necessity for the purposes of the legitimate interests pursued by the controller or by a third party.
Collected Data may be processed if mandated by law.
Please note that the legal basis under EU law for this processing is Article 6 (1) (c) General Data Protection Regulation, the necessity for compliance with a legal obligation.
The Collected Data that is communicated to and stored by Sony will be made available to Amazon, if you choose to use compatible voice control device, in order to provide you with this service, and to other Sony group companies and third party service providers, as follows:
To link your TV and the Amazon Alexa compatible device via this Application, Sony will share the following Collected Data with Amazon:
TV name (that you have entered yourself into the Application)
The state of your TV (such as power state, play back state, volume of sound, use of each channel and external input)
Amazon Access token
UUID issued by Sony’s cloud service
Access token of Sony’s cloud service
Authorization code of Sony’s cloud service
For more information, please see Amazon’s Website ( https://www.amazon.com/gp/help/customer/display.html?nodeId=201809740 ), which also explains where and how such Collected Data collected by Amazon can be deleted.
The Collected Data will be sent and stored in Sony’s server which is managed by Sony Electronics Inc., established in the United States, for the purposes of pursuing the activities outlined in Sections 3 (How does Sony use the Collected Data?) above. Sony has implemented appropriate safeguards to ensure these data transfers are made in compliance with applicable local laws.
If you contact your local Sony group companies in relation to questions about the Application, Sony may need to share the Collected Data with that Sony group companies to assist with your request. Sony may otherwise share Collected Data with Sony group companies for other purposes set out in this Privacy Policy.
Sony may use third party service providers to store and process the Collected Data on their behalf for the purposes set out in this Privacy Policy. Such third parties include, but are not limited to, IT service providers and data hosting providers.
In the event that Sony sells or transfers a portion or all of its business, the Collected Data may be transferred by Sony to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer. Sony will continue to ensure the confidentiality of the Collected Data before such transaction occurs, and after such transaction, Sony will delete the Collected Data as soon as reasonably practicable after such transaction.
The Collected Data may be disclosed to government authorities and/or law enforcement officials if required by the applicable laws.
Sony 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 Sony believes necessary to comply with our legal obligations.
Sony will retain the Collected Data described in Section 2 for approximately 6 months after your last access to this Application and the compatible voice-control device application. If you would like to delete the Collected Data collected via this Application or if you would like to withdraw your consent, you can go to [Home] > [TV Control with Smart Speakers] > [Settings] > [Privacy Policy], at any time. Alternatively, please contact us at the address set out below and Sony will respond in a reasonable time. After you withdraw your consent, Sony will stop using the Collected Data, and the Collected Data will be deleted automatically after 6 months. Please note that Sony may be required to retain certain Collected Data by law. Where Sony no longer requires the Collected Data, it will be destroyed or de-identified in line with our internal information security policies.
The Collected Data will be processed, stored and transferred for the purposes outlined in Sections 3 (How does Sony use the Collected Data?) from your country of residence to Japan, EU (Ireland) and the United States. The Collected Data will be processed by staff operating outside your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries. 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. Courts, law enforcement, and other authorities in countries/regions outside your residence may be entitled to access Collected Data upon its transfer.
[For residents in EEA and UK]
Sony takes appropriate measures to ensure that all transfers of Collected Data to outside of the EEA/the UK meet the requirements of applicable EU and UK data protection legislation. As the Collected Data will be transferred to and processed in countries outside the EEA and the UK, where the privacy laws may not provide an equivalent level of protection to those in your home country, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the European Commission or the UK Government, the Collected Data is adequately protected by Standard Contractual Clauses approved by the European Commission which can be accessed at https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en, the addendum to the EU Commission’s standard contractual clauses or standalone international data transfer agreement approved under the UK data protection law (as applicable) or a stakeholder’s/vendor’s Processor Binding Corporate Rules. If you have questions or concerns about Sony's data transfer arrangements, or if you require a copy of the relevant mechanism, please contact us as described in Section 12. Contact Us below.
Sony establishes a common policy, which are built upon industry standards and best practices like the International Organization for Standardization (ISO) 27001 family of standards and National Institute of Standards and Technology (NIST) standards and adopts strict security control measures for personal data collected and possessed by Sony. These measures include implementation and periodical review of organizational information security management system, periodical training and awareness program, periodical inventory of information assets, physical security control measures (employee access control, client control, etc.), encrypted communications, strict access control, periodical vulnerability assessment of information systems, etc.
Whenever Sony uses service providers (including subcontractors) to process the personal data, Sony confirms that such service providers (including subcontractors) have adopted the necessary and appropriate security control measures. In addition, Sony also expresses its basic policy on handling of personal information in the “Sony Group Japan - Common Corporate Privacy Policy” (https://www.sony.co.jp/privacy-policy/). Please refer to such policy as well for an overview of security control measures.
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 Application is intended for a general audience; the Application 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 Sony with personal data/ personally identifiable information (as defined by applicable law) without your consent, you should contact us at the address set forth as indicated below.
In some countries, you have certain rights with respect to personal data Sony holds about you. These may include the rights to request a copy of 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, blocks/restrict processing and/or use of such Collected Data if it is inaccurate. You may also object to Sony’s processing of Collected Data. In some countries, you may also ask us to provide some types of the Information 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 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 contact us at the address in Section 12 (Contact Us). 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 EEA and UK residents]
In some countries/regions, you have certain rights with respect to the Collected Data Sony holds about you. These may include the rights as indicated below. 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 may have the right to:
You can exercise these rights by using the Section 12 (Contact Us) details below.
These rights may be limited, for example, if fulfilling your request would reveal personal information 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.
Please note that automated decision-making including profiling, which produces legal or other similar material effects currently does not take place on our Application(s) with regard to Collected Data for the purposes set in this privacy policy.
If you have unresolved concerns, you have the right to complain to a data protection authority in the country where you live, work, or where you believe a breach has occurred. Details of EU data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en and the website of the data protection authority of the UK Information Commissioner’s office is https://ico.org.uk/make-a-complaint/.
[Notice to US and Canada Residents]
(i) Notice to Residents of U.S. States (excluding CA)
We set forth in our Privacy Policy and List 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.
Consumers in certain states with comprehensive privacy laws 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:
https://products.sel.sony.com/SEL/legal/DataRequests.html .
(ii) Notice to California Residents: California Privacy Notice
This California Privacy Notice is effective as of May 1, 2024.
This California Privacy Notice supplements our Privacy Policy and applies only to California residents. This notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act, as amended 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 Personal Information:
Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable fields of information in the submission form. 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. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill the 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 fulfil your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we may not be able to process the 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:
https://products.sel.sony.com/SEL/legal/DataRequests.html
; or you may call us toll-free at 1-833-681-9900.
Data Retention
We retain Personal Information 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 as long as you use the Application. We either delete your personal information or de-identify it after approximately 6 months from the collection of such data, except as otherwise required by law.
Data Reporting. To access our CCPA data reporting metrics for the previous calendar year, go to: https://electronics.sony.com/DSR-metrics .
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 TV. 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 following business or commercial purposes described in List 1:
List 1
For more information about our local Sony electronics affiliate’s California privacy practices, please refer to this California-specific information here: https://electronics.sony.com/privacy-policy#DataPractices
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 – TV Control with Smart Speakers Application (Amazon)”. 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– TV Control with Smart Speakers Application (Amazon)” 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.
Further Information for Residents in Québec, Canada
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. All Sony personnel handling personal information will be subject to a duty of confidentiality and to ensure that all personal information is handled in accordance with standard security measures. By using the TV, you acknowledge and agree that your personal information will be transferred outside of Quebec.
We will only use your personal information for the purposes stated at the point of collection, or as otherwise noted in this privacy policy.
Automated Decision Making: Sony does not use personal information to render any decisions based exclusively on an automated processing of such information.
Location Tracking: We may use automated technologies to collect information about your general location, such as your country. 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:
Exercising your rights: If you are a Quebec resident and wish to exercise your right(s), please: submit your request here: https://sony-privacyportal.my.onetrust.com/webform/ae4501a4-318f-4210-bddc-9a8bc984c5a6/0c8ea26c-76a5-4bcd-9ef5-3597f99e021a; or you may call us toll-free (within Canada) at: 1-888-494-7669.
Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.
Our Privacy Officer is in charge of the protection of personal information.
Contact Information for Sony’s Privacy Officer:
Sony of Canada, ULC.
Attn: Privacy Officer, Law Department,
2235 Sheppard Avenue East, Suite 800
Toronto, ON M2J 5B5
Telephone: 1-888-494-7669 (toll free within Canada)
Email: privacy@am.sony.com
You may submit a complaint to the Commission d’accès à l’information du Québec (CAI) by visiting: https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.
[For Asia & Oceania Residents]
Please read this Privacy Policy carefully because by using this Application, you will be deemed to have agreed and consented to the terms of this Privacy Policy.
By using this Application, or providing us with any Collected Data, you fully understand and consent to the transfer of the Collected Data internationally, processing and storage of such Collected Data in the United States 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.
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 Collected Data to a third party, such as an overseas authority.
By using this Application, or providing us with any Collected Data, you agree that you will not hold Sony or Sony Affiliates liable for 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 (Who else has access to the Collected Data?) takes place.
This Privacy Policy may be updated from time to time for any reason. Sony will notify or request your consent (whenever necessary under the applicable law) for any changes to our Privacy Policy.
You are advised to consult the posted Privacy Policy regularly for any changes.
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 your personal Collected Data, please contact us at the address as indicated below.
Sony Corporation, a Japanese company, is the controller for the Collected Data. Our representative in the EU is Sony Europe BV, a Dutch company, whose business address is Taurusavenue 16, 2132LS Hoofddorp, the Netherlands.
If you have any concerns about how we process your data, you can contact our representative in the EU and EEA:
By email: privacyoffice.seu@sony.com
By post: Sony Europe BV, Taurusavenue 16, 2132LS Hoofddorp, the Netherlands
You can also contact your local Sony group companies at https://sony-europe.com.
Sony Corporation, a Japanese company, is the controller for the Collected Data. Our representative in the UK is Sony Europe BV, a Dutch company, whose UK branch has its business address in The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom.
If you have any concerns about how we process your data, you can contact our representative in the UK:
By email: privacyoffice.seu@sony.com
By post: Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom
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
Americas other than the US :
For Mexico, Central and South America and the Caribbean:
Regional Latin America Privacy Office at https://www.sony-latin.com/corporate/SOLA/home.html
Africa and Middle East: https://www.sony-mea.com/en/locale-selector
Asia & Oceania: https://www.sony-asia.com/locale-selector
Japan: http://www.sony.jp/support/
Amazon, Alexa, and all related logos and motion marks are trademarks of Amazon.com, Inc. or its affiliates.
