Last Updated: [March, 2023]
This Privacy Policy sets out how Sony Corporation, of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan (“Sony”, “we”, “our” or “us”) collects, uses, stores and otherwise processes the Collected Data (defined below) through certain subpages of Sony.net (https://www.sony.net) (“Website”), online activities described below, and any other activities or offerings that post a link to this Privacy Policy. It also describes your data protection rights, including the right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 “Privacy Rights” or in Section 11 below.
Other websites or properties of Sony Group Companies including some that are linked to/from the Website, may have different privacy policies; and some of the subpages of this Website may have additional privacy notices to cover activity not covered by this Privacy Policy: therefore, please review the privacy policy or privacy notices on those websites or properties if you visit them.
This privacy Policy explains the types of information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information.
For the purposes of the GDPR and other 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.
"Sony Group Companies" means 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).
For our use of Cookies and similar technologies, please also see our Cookie Policy.
We have provided some additional information for individuals located in the European Economic Area ("EEA") and the UK (together, "EEA/UK Individuals").
Sony collects data as described below which may include personal information (collectively, the "Collected Data") related to your use of the Website.
Sony processes your Collected Data for the purposes listed hereafter:
For EEA/UK Individuals: The legal basis for the processing above is the legitimate interest of Sony.
Product/service improvement, market research and analytics
Sony will use Collected Data it collects, to improve the functionality and user experience of Website and Sony's products and services.
We work constantly to improve our products and services. We either base this processing on our legitimate interests to gauge product performance and customer satisfaction, to develop our products and services to better meet customer requirements, to ensure data quality, to develop identity management, and to strengthen network and information security, or on your prior consent. In this context, we may use personal information:
For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for Sony's legitimate interests as described above.
Sony processes Collected Data in order to comply with applicable law and regulations, this includes responding to requests from government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws.
For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for compliance with a legal obligation.
We retain Collected Data for as long as we continue to make the Website available to customers, and for a further 6 months following discontinuation, at which point the information will either be anonymized or destroyed. Please note that we may be required to retain certain information by law.
Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy from your country/regions of residence to countries/regions outside your country/region of residence, including Japan and the US. Collected Data will be processed by staff operating outside your country/region of residence who work for us or for one of our service providers, including in the locations set out in Section 3 above. Some of the countries and regions may not provide the same level of data protection as your country.
For EEA/UK Individuals: 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.
Where information is transferred outside the EEA and the UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the UK Government, the personal data is adequately protected by the vendor's EU / UK Processor Binding Corporate Rules, the EU Commission's approved standard contractual clauses which can be accessed here or the addendum to the EU Commission's standard contractual clauses or standalone international data transfer agreement approved under UK data protection law (as applicable). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive to protect Collected Data, we cannot guarantee or warrant the security of any information transmitted to us through your use of the Website or 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. The Website is not directed to and does not knowingly collect personal information from children under the age of 18. 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 processes about you. These may include the right to request a copy of the Collected Data that Sony holds about you and/or you may request that Sony corrects, deletes, blocks/restricts processing of such Collected Data. You may also object to Sony's processing of Collected Data. In some countries, you may also ask us to provide your Collected Data to you in a structured, machine-readable format and ask us to share (port) such data with another organisation. These rights may be limited, for example, if fulfilling your request would reveal Collected 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 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 Collected Data, you have a right to lodge a complaint withyour national or any other data protection supervisory authority.
Where we collect Collected Data to administer our contract with, this is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of the requested Collected Data is optional, but this may affect your ability to use the services or use particular aspects of the services where the information is needed for those purposes.
For EEA/UK Individuals:
You have the right to:
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.
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.
If you have any questions or concerns about this Privacy Policy or if you wish to exercise any legal right you have in respect of Collected Data, you can contact local Sony Group Companies using the contact details that can be found at Country/Region | Sony Electronics
We set forth above in our Privacy Policy 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.
Virginia Consumers have the following rights with respect to their personal data subject to the meanings and exceptions set forth in the Virginia Consumer Data Protection Act ("VCDPA"):
If you are a Virginia Consumer and would like to exercise any of these rights, please complete the form here: Data Requests.
Opt-out of Targeted Advertising: Virginia Consumers have the right to opt-out out of the processing of your Personal Data for the purposes of targeted advertising. Sony engages in online advertising and analytics practices that may be considered "targeted advertising" under the VCDPA. To exercise your rights to opt-out of targeted advertising, you may submit a request here: Opt-out of Targeted Advertising.
In addition, you may need to disable sharing through cookies set by 3rd parties on certain Sony websites which may be considered targeted advertising under the VCDPA. To manage your cookie preferences, please refer to the
"Manage Cookies" link on the cookie banner or in the footer for the applicable website and ensure that "Targeting Cookies" are disabled.
While the VCDPA also permits you to opt-out of the sale of your Personal Data, at this time we do not engage in the sale of Personal Data to third parties for monetary compensation. Similarly, we do not process your Personal Data for purposes of profiling as set forth in the VCDPA that would require such an opt-out.
VCDPA Appeals
Pursuant to the VCDPA, if, for any reason, you would like to appeal a decision made by us relating to your request, you have the right to submit an appeal and can do so by completing this form: Data Requests. Please include your full name, the basis for your appeal, and any additional information to consider.
This California Privacy Notice is effective as of [March, 2023].
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 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 CA Personal Information:
"Limit the Use and Disclosure of Sensitive Personal Information." Under the CPRA, we must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information 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. Sony's use and disclosure of Sensitive Personal Information is not used for such purposes and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
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 can't respond to your request if we can't verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. 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 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 will not be able to process the request.
Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sale or Sharing.
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 Probate Code sections 4000-4465. 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. 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.
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.
For requests to know, 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.
Right to Opt-Out of Sale/Sharing
California Consumers have the right to opt-out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). California Consumers also have the right to opt-out of the "sale" of your Personal Information for monetary or other valuable consideration. Please note that we do not sell Personal Information for monetary or other valuable consideration. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale or Sharing, please submit your request at: Do Not Sell or Share My Personal Information.
Cookie Based Opt-Outs for Do Not Sell or Share for Cross Context Behavioral Advertising
Sony engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CPRA. In addition to submitting the form above, you may need to disable sharing through cookies set by 3rd parties on certain Sony websites. To manage your cookie preferences, please refer to the “Manage Cookies” link in the cookie banner or footer for the applicable website and ensure that “Targeting Cookies” are disabled
We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using the Website or continuing to interact with us.
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.
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
The Personal Information we collect about you will depend upon how you use the Website or otherwise interact with us. 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 the CPRA.
We may have used Personal Information for the following business or commercial purposes:
| Categories of Personal Information Collected | Business or Commercial Purposes for Collection of Personal Information | Categories of Sources from Which Personal Information Was Collected | Categories of Third Parties to Whom We May Disclose Personal Information for a Business Purpose | Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared for Cross Context Behavioral Advertising |
|---|---|---|---|---|
| Identifiers Such as name, phone number, mailing address, email, and online or device identifiers such IP address |
We may use this type of information to: Provide requested services; respond to your inquiries; personalize your experience on our websites, apps and online; maintain and improve our products and services; monitor and maintain security of our systems and prevent fraud; internal business, legal and compliance purposes |
We may collect this type of information from: Consumers; Sony Group companies; Third-Party Business Partners; Cookies and Tracking Technologies |
We may disclose this type of information to: Sony Group companies; Service Providers; Data Analytics and Advertising Providers; Business Partner;. |
Third party advertising, analytics, and other similar marketing business partners may have access to this data, and this may be considered a "sale" or "share" under the CPRA under certain circumstances. |
| Internet or Other Electronic Network Activity This category includes information such as computer and connection information, browser type, operating system, page views, traffic to and from the websites, advertising data and other standard weblog information collected via cookies, web beacons, and related tracking technologies. |
To personalize your experience on our websites, apps and online; maintain and improve our products, services and features; serve advertising; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes | Consumers; Sony Group companies; Third Party Applications; Advertising Networks | Sony Group companies; Service Providers; Data Analytics and Advertising Providers; Advertising Networks; Legal Authorities (as required by law); Business Transfer Recipients. | Third party advertising, analytics, and other similar marketing business partners may have access to this data, and this may be considered a "sale" or "share" under the CPRA under certain circumstances. |
| Inferences Drawn from Other Information and Consumer Characteristics These may relate to demographics , interests or hobbies, and inferences drawn from collected information, browsing history. |
To develop and deliver marketing communications; to personalize your experience on our websites, apps and online; develop, maintain and improve the products, services and features offered by us and the Sony Group companies | Consumers; Sony Group companies; Third-Party Business Partners; Third Party Applications; Consumer Data Providers | Sony Group companies; Service Providers; Data Analytics Providers; Advertising Networks; Legal Authorities (as required by law); Business Transfer Recipients. | Third party advertising, analytics, and other similar marketing business partners may have access to this data, including to serve you more relevant advertisements, and this may be considered a "sale" or "share" under the CPRA under certain circumstances. |
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 companies 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." We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
