PRIVACY POLICY FOR “SONY | HEADPHONES CONNECT” APPLICATION

This Privacy Policy applies to “Sony | Headphones Connect” (the “Application”). The Application is a mobile application dedicated to wireless headphones from SONY, and it allows you to customize the sound from your headphones according to your preference.

In this Privacy Policy, we use “SONY,” "we," "us," and "our" to refer to Sony Home Entertainment & Sound Products Inc. “SONY Affiliates” shall mean Sony Corporation, which is the ultimate parent company of SONY and any legal entities controlled by Sony Corporation. SONY and SONY Affiliates shall be collectively referred to as “SONY Group”. 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.

1. SUMMARY OF KEY POINTS

2. What information do we obtain?

SONY uses information or data as described below which may include personal information (collectively, the “Collected Data”) collected automatically related to your use of the Application.

(ⅰ) Information about your device on which the Application is installed (the “Installed Device”) and component parts thereof:

(ⅱ) Information about the Application:

(ⅲ) Information about the device which is connected to the Installed Device and which is detected by or registered to the Application (namely, your SONY headphones products, “Related Device”):

The Collected Data collected automatically as described above will be uploaded with a unique number assigned to the devices on which the Application is installed and will allow SONY Group to distinguish the data received from the device from those received from other devices.

Sony uses the above Collected Data for the purpose set forth in Section 3 and as long as it is necessary to provide you with the features and functions of the Application.

3. How does SONY use the Collected Data?

Improvement and development of current and future products and services of SONY Group

We use the Collected Data listed in Section 2 to improve and develop SONY’s and SONY Group’s current and future products and services.

Where you select “Agree and Proceed,” then we process the Collected Data because you have given us your consent.

You can withdraw your consent above at any time by selecting "(3 dots) Menu" > "About this app" > "Privacy settings" in the Application.

Legitimate interests

We also process the Collected Data where this is necessary for SONY Group to pursue its legitimate interests in delivering the Application and related services or products to you, including;

4. Who else has access to the Collected Data?

The Collected Data that is communicated to and stored by SONY may be made available to SONY Affiliates and to other third parties, as follows:

SONY Affiliates

The Collected Data may be shared with and used by other SONY Affiliates for the purposes of pursuing the activities outlined in Section 3 above.

Third party contractors

SONY and SONY Affiliates may use third party contractors to process or analyze the Collected Data on their behalf for the purposes set out in this Privacy Policy.

Business transfer

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

Compliance and enforcement

SONY may retain, use and/or disclose any of the Collected Data if required or permitted by law, regulation or order or if required for us to protect our legitimate interests, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend itself, or others, against illegal, criminal or harmful activities.

5. Data Retention

SONY will collect the Collected Data described in Section 2 for as long as you use the Application and such Collected Data will be deleted within twenty-seven (27) months from the date of such collection.

If you'd like SONY to delete user provided data that you have provided via the Application and/or online services, please contact SONY at www.sony.net/SonyInfo/Support/ and SONY will respond in a reasonable time and manner. Please note that some or all of the user provided data may be required in order for the Application and/or online services to function properly, and SONY may be required to retain certain Collected Data by law.

6. Transfer of the Collected Data internationally

The Collected Data will be processed, stored and transferred for the purposes outlined in Section 3 to countries/regions outside the European Economic Area (EEA) and/or your country/region of residence, including in particular Japan and the United States. The Collected Data will be processed by staffs operating outside the EEA and/or your country/region of residence, who work for SONY Group or for one of SONY Group’s service providers and may be seen by such staff in those countries/regions. As the Collected Data about you will be transferred to and processed in countries/regions outside the EEA, where the privacy laws may not provide an equivalent level of protection to those in your home country/region, and where this is to a stakeholder or vendor in a country/region that is not subject to an adequacy decision by the European Commission, the Collected Data is adequately protected by Standard Contractual Clauses approved by the European Commission, an appropriate Privacy Shield certification or a stakeholder’s/vendor’s Processor Binding Corporate Rules. If you have questions or concerns about SONY's data transfer arrangements, please contact us, using the contact information below.

7. 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 Application or that SONY stores on its systems or that is stored on SONY’s third party contractors' systems.

8. SONY Group’s Policy Regarding Children

SONY Group 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. If you are a parent or guardian and are concerned that your child has provided a SONY Affiliate with the Collected Data without your consent, you should contact such SONY or SONY Affiliate as indicated below.

9. Privacy Rights (including California Privacy Rights and EU data protection rights)

In some countries/regions, including countries in the EEA, you have certain rights with respect to the Collected Data SONY or a SONY Affiliate holds about you. These may include the right to request a copy of the Collected Data that SONY or a SONY Affiliate holds about you and/or you may request that SONY or the SONY Affiliate corrects, amends, deletes or blocks/restrict such Collected Data if it is inaccurate. You may also 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 SONY at www.sony.net/SonyInfo/Support/

You also have the right to complain to a supervisory authority for data protection 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 the Collected Data.

As of January 1, 2005, California Civil Code Section 1798.83 (the "Code") permits users who are California residents to request certain information regarding the disclosure of personal information to third parties which is used for their direct marketing purposes. To make such a request, to which SONY shall respond to the extent required by the Code, contact SONY Personal Information Management Office at this email: Privacy@am.sony.com

10. Changes

SONY will notify you of any changes to SONY’s Privacy Policy by posting the new Privacy Policy here http://policies.songpal.sony.net/headphones/pp/20190305/pp/hpc_pp_en.html and by prominently posting notice of the amendment on the Application. You are advised to consult the posted Privacy Policy regularly for any changes.

11. Contact Information

This Privacy Policy applies to: SONY as a data controller. SONY's address is Sony City Osaki, 2-10-1, Osaki, Shinagawa-ku, Tokyo, 141-8610, Japan.

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 the Collected Data, please contact us at www.sony.net/SonyInfo/Support/

If you are in the EU: Sony Home Entertainment & Sound Products Inc., 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 by emailing:privacyoffice.SEU@sony.com. You can also get in touch by writing to Sony Europe BV at the address above or at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.

If you are in the United Kingdom: Sony Home Entertainment & Sound Products Inc., 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 emailing:privacyoffice.SEU@sony.com. You can also get in touch by writing to The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.


Effective Date: This Privacy Policy is effective as of June 3, 2019.


© 2017,2018,2019 Sony Home Entertainment & Sound Products Inc.