1. Information that Sony collects

When you use the Services, Sony collects information listed below 1.1 - 1.7 (“Collected Data") from you.
The Collected Data may be linked and processed in conjunction with the information received from third parties including Sony Group Companies.

Sony provides a fingerprint authentication function on the Device. When you use the function, the Device will collect and read the fingerprint information with the purpose of fingerprint verification only. Your fingerprint information is stored only in the Device and is not sent off from your Device. It’s never stored in Sony’s server or collected by Sony.

1.1 Information about the Device

• Information about the Device’s hardware (e.g., model name, device IDs such as IMEI)
• Information about the Device’s software(e.g., OS and firmware information)
• Mobile carrier information (e.g., mobile carrier name, code identifying the carrier, service providing country/region)

• <Collection method>
  • Sony collects the above information automatically when you use the Device (e.g., when you perform the first startup, when you update the software, when you connect the Device to the network).
  • Sony collects the above information directly from the Device when you receive repair services.

1.2 IP address

• <Collection method>
  • Sony collects the above information automatically when you use the Device (e.g., when you perform the first startup, when you update the software, when you connect the Device to the network).

1.3 Information of the network to which the Device is connected

• Information about usage and quality of your network (mobile networks, Wi-Fi and Bluetooth) connections
• Location estimated from the cell tower information of mobile networks

• <Collection method>
  • If you give us a separate consent (please refer to 2.2, 2.3 and 2.4), Sony collects the above information automatically when you connect the Device to the network.

1.4 The Device’s usage status

• Settings Information
• Battery level
• System activity
• Information regarding products which are connected to the Device (e.g., type, number, model name of connected devices and connection method such as USB or Bluetooth)
• Information about crashes, errors and other problems
• Whether or not you have a Google account signed in on the Device

• <Collection method>
  • If you give us a separate consent (please refer to 2.2, 2.3 and 2.4), Sony collects information automatically when you use the Device. These collections may occur periodically or when you use certain the Device features. This timing depends on which data is collected.
  • Sony collects the above information directly from the Device when you receive repair services.

1.5 Usage status of applications

• Name of the application installed on the Device (including the Application), number of usage, start time and end time of use, usage duration, power consumption information, data transmission volume and information about crashes, errors and other problems
• Specific usage of the Applications (e.g., logs regarding the operation of each function of the Applications)
• Artist name, the number of music and albums registered on the Application “Music”, start time of music listening and duration of music listening

• <Collection method>
  • If you give us a separate consent (please refer to 2.2, 2.3 and 2.4), Sony collects the above information automatically when you use applications.

1.6 Call information

• Call environment and sound volume
• Start time and end time of a call and duration of a call
• Whether or not the call was terminated due to a malfunction

• <Collection method>
  • If you give us a separate consent (please refer to 2.2, 2.3 and 2.4), Sony collects the above information automatically when you make a call with the Device.

1.7 Responses to the survey

• <Collection method>
  • Sony may ask you through each of the Services whether you would like to participate in the survey. If you can answer the survey, Sony collects your response information.

2. How Sony uses the Collected Data?

We use the Collected Data for the following purposes:

2.1 Keeping the Services running

Sony collects and uses the following information to provide the Services. This includes making necessary notifications and providing software updates.

<Information used for this purpose>
Information listed in 1.1 and 1.2

Please note that the legal basis under for this processing is the performance of the contract that we have with you.

2.2 Improving Sony products and services

If you give us a separate consent on the Device’s setting page, Sony collects and analyses the following information to understand your use of the Services to improve and develop Sony products and services. Sony may analyze such information in conjunction with the information collected through other Sony products and services if you use one of those.

<Information used for this purpose>
Information listed in 1.1, 1.3, 1.4, 1.5, 1.6 and 1.7

Please note that your consent forms the legal basis for this processing under EU-law.

You can withdraw your consent at any time by [Settings] > [About phone] > [Detailed Diagnostics]

2.3 Marketing and advertisement

If you give us a separate consent on the Device’s setting page, Sony will collect and share with Sony Europe B. V. (“SEU”) your information below. Sony and SEU will be able to evaluate and better understand your preferences and interests and SEU will be able to provide you with relevant offers, recommendations, news and updates via email, apps, and websites. For the details of SEU’s data processing, please refer to SEU’s privacy policy.

<Information used for this purpose>
Information listed in 1.1, 1.3, 1.4, 1.5 and 1.7

Please note that your consent forms the legal basis for this processing under EU-law.

You can withdraw your consent at any time by [Settings] > [About phone] > [Xperia service setting]

If you give us a separate consent on the Application “Support”, Sony will collect and use your data to be able to provide you with offers, recommendations, news, updates and survey requests via push notifications generated by “Support” App on behalf of SEU. For the details of SEU’s data processing, please refer to SEU’s privacy policy.

<Information used for this purpose>
Information listed in 1.1, 1.3, 1.4, 1.5 and 1.7

Please note that your consent forms the legal basis for this processing under EU-law.

You can withdraw your consent at any time by tapping [⁝] (three dots menu) > [Settings] > [Privacy settings] on the “Support” app.

2.4 Providing tailored support

Sony offers support services including tailored support on the Application “Support”. If you give us a separate consent on such Application, Sony collects and uses information below to provide you with more enhanced and personalized support services.

<information used for this purpose>
Information listed in 1.1, 1.3, 1.4, 1.5 and 1.6

Please note that your consent forms the legal basis for this processing under EU-law.

You can withdraw your consent at any time by [⁝ (three dots menu)] > [setting] > [Privacy settings] on the Application “Support”.

3. Who else has access to the Collected Data?

The Collected Data that is communicated to and stored by Sony may be made available to the following entities:

3.1 Sony Europe B. V.

The Collected Data may be shared with and used by SEU as an independent controller for the purposes of “2.3 Marketing and advertisement”.

3.2 Service providers

Sony may use third party service providers to process the Collected Data on its behalf for the purposes set out in this Privacy Policy. Such third parties include IT service providers and data hosting providers. Our hosting provider is Amazon Web Services in Ireland, acting as our processor.

3.3 Professional advisers

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 to help us fulfil our legal obligations.

3.4 Business transfer

In the event that Sony or SEU sells or transfers a portion or all of its business, the Collected Data may be transferred by Sony or SEU to the purchasing or acquiring entity as part of the transaction.

3.5 Government Authorities/ Law Enforcement Officials

The Collected Data may be disclosed to government authorities and/or law enforcement officials if required by the laws or if necessary for us to protect our legitimate interests, or the interests of others, in compliance with applicable law.

4. Transfer of the Collected Data internationally

The Collected Data will be processed, stored and transferred for the purposes outlined in “2. How Sony uses the Collected Data?” to countries/regions outside the European Economic Area (EEA), Switzerland and/or the UK and/or your country/region of residence, including in particular Japan. Sony takes appropriate measures to ensure that all transfers of Collected Data to outside of the EEA/the UK and Switzerland 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, Switzerland 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 here, 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 “10. Contact Information”.

5. 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 the Services or that Sony stores on its systems or that is stored on Sony’s third party contractors' systems.

6. Data Retention

SONY will retain the Collected Data for the following periods as long as it is necessary for the relationship with you and to pursue the purposes detailed in “2.How SONY uses the Collected Data?” or otherwise permitted or required under applicable law.

• Collected Data listed in 1.1
  Sony will apply a maximum of 10 years retention period from the date of the collection of the Collected Data.
• Collected Data listed in 1.2
  Sony will apply a maximum of 30 dates retention period from the date of the collection of the Collected Data.
• Collected Data listed in 1.3, 1.4, 1.5, 1.6 and 1.7
  Sony will apply a maximum of 5 years retention period from the date of the collection of the Collected Data.

Please note that Sony may retain Collected Data for an appropriate period when it needs to respond to your requests or inquiries, to detect, prevent, address and analyse security or technical issues, or to the extent permitted by applicable law.
If Sony no longer needs to retain the Collected Data, we will either anonymize or delete it in accordance with our information security policy.

7. Policy Regarding Children

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 and applicable local legislation in other countries/regions. The Services is intended for a general audience; the Services is not directed to and does not knowingly collect personal information from children. 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 a Sony with personal information (as defined by applicable law), you should contact us as indicated below.

8. Privacy Rights

In some countries/regions, you have certain rights with respect to the Collected Data that Sony or Sony Europe B.V. holds about you. These may include the right to request a copy of the Collected Data that Sony or Sony Europe B.V. holds about you and/or the right to request that Sony or Sony Europe B.V. amends, deletes, blocks/restricts or corrects such Collected Data if it is inaccurate. You may also have the right to ask us to provide some types of the Collected Data to you, or another organization nominated by you, in a structured and machine readable format. In addition, you can object to the processing of the Collected Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
If you would like to exercise any of these rights, please contact us as described in “10. Contact Information”.
Please note that automated decision-making including profiling, which produces legal or other similar material effects currently does not take place on our Services 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 here and the website of the data protection authority of the UK Information Commissioner’s office is here.

9. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (if necessary under applicable law) of any changes to this Privacy Policy.
With regard to notification, it may be sent to you through different channels, for example, a notice on our website or notification on the Device”.

10. Contact Information

Sony, a Japanese company, is the controller for the Collected Data. Sony's address is 1-7-1 Konan Minato-ku, Tokyo, 108-0075 Japan.
If you have any questions or concerns about this Privacy Policy or our use of the Collected Data, or if you wish to make requests or exercise any legal right you may have in respect of the Collected Data, please contact us in the following ways:

1. Via our online web form:
   • /support/en/contacts/pim/email
2. By email:
   • You can also contact us by emailing privacyoffice.SEU@sony.com.
3. By mail:
   • If you are in the European Economic Area (“EEA”) or Switzerland
     You can write to us at our business address above, or at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.
     If you are in the UK
     You can write to our UK branch at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.
4. By telephone:
   • If you are calling from England, Wales & Scotland, please dial 0844 8466 555
     9am to 6pm, Monday to Friday.
     4p per minute from a standard BT line, charges from other networks may vary.
     If you are calling from Northern Ireland or Eire, please dial (00 353) 1 413 1771 9am to 6pm, Monday to Friday.