PRIVACY POLICY FOR “SONY | HEADPHONES CONNECT” AND “SONY | 360 SPATIAL SOUND PERSONALIZER” APPLICATIONS

Effective Date: This Privacy Policy was revised and is effective as of April 1, 2021.


This Privacy Policy applies to “Sony | Headphones Connect” (the “Headphones Connect”) and “Sony | 360 Spatial Sound Personalizer” (the “360 Spatial Sound Personalizer”) (collectively, the “Application(s)”). This Privacy Policy explains our collection, use, sharing and other practices regarding your data when you use each Application. Headphones Connect 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.

360 Spatial Sound Personalizer is a mobile application that allows you to enjoy personalized 360 Reality Audio settings on compatible Sony products by using the camera of your mobile device.

In this Privacy Policy, we use “SONY,” "we," "us," and "our" to refer to Sony Corporation. “SONY Affiliates” shall mean 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. This Privacy Policy only applies to the Applications and is in addition to any other privacy policy that may apply to your interactions with SONY and SONY Affiliates or any third party, regarding their product, software or service.

1. SUMMARY OF KEY POINTS

2. What information does SONY collect?

SONY collects and uses information or data as described below. Some of this information may be considered personal information under applicable law in your jurisdiction, and it is collected when you choose to provide information to us or automatically when you use the Application (collectively, the “Collected Data”).

(A) Information collected when you create a SHES Account:

(i) Sign-in authentication

If you decide to activate certain services, such as the Backup and restoration of settings service described in section 3. (A) (i) , you will be required to create a Sony’s cloud service account for Home Entertainment & Sound Products (“SHES Account”) according to the [Terms of Use] and [Privacy Policy].

In order to create an SHES Account, you will first need to provide sign in authentication via a Sony account (SHES Cloud service).

More information about the data we collect in connection with each authentication method is below. We use cookies, activation codes and/or tokens as necessary for us to provide you SHES Account service or to link your device to a service.

When you create a Sony account (SHES Cloud service), SONY will collect the following:

Once you have successfully signed into your Sony account (SHES Cloud service), your mobile device will receive a digital ‘access token’ from this Sony account (SHES Cloud service). Please be aware that some Sony accounts for other Sony group services will be linked automatically if you use the same sign-in ID and password. For more information about linking accounts, please go: https://acm.account.sony.com/linking-account

For password management and authentication, you can also register a security question and answer and telephone number at the Sony account (SHES Cloud service) security setting page. This Collected Data is not used for any other purpose.

(ii) SHES Account

After you have completed sign-in authentication, you will create your SHES Account and we will assign identifiers, issue tokens and collect the following information you provide:

Please note that you may create separate SHES Accounts for each email address you choose to use.

(iii) Backup and Setting Restoration

In order to provide you the Backup and Restoration of Settings service of Headphones Connect, and personalized 360 Reality Audio settings service of 360 Spatial Sound Personalizer, we will collect and store settings of the Related Device (defined below) according to the Application (i.e. Adaptive Sound Control, automatic download of software settings, and 360 Reality Audio setting) (“Related Device Settings Data”) and link this information with your respective SHES Account. The Adaptive Sound Control settings include Registered Location data and the adjusted settings of the Related Device (e.g. noise cancelling) for the Registered Location. Please note that if you set up more than one SHES Account, each SHES Account may contain separate Related Device Settings Data.

(B) Information collected through Headphones Connect

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

(ⅱ) Information about Headphones Connect:

(ⅲ) Information about your SONY headphone product(s) connected to the Installed Device and which is detected by or registered to the Headphones Connect including settings (“Related Device”):

(ⅳ) Information collected by surveys:

Sony uses the above Collected Data for the purposes set forth in Section 3 below, as strictly required to fulfill these purposes in order to provide you with the features and functions of Headphones Connect.

(C) Information collected through 360 Spatial Sound Personalizer

(i) Information about the device on which the 360 Spatial Sound Personalizer is installed (the “Installed Device”) and component parts thereof:

(ii) Information about the 360 Spatial Sound Personalizer:

3. How does SONY use the Collected Data?

In addition to providing you the features/functions of each Application and the related services, SONY uses your Collected Data for the following purposes:

(A) Headphones Connect

(i) Backup and Restoration of Settings service

Headphones Connect provides a backup and restoration of settings service linked with your SHES Account, whereby the Related Device Settings Data is uploaded to and stored on our servers (“Backup and Restoration of Settings”). This enables you to backup and restore your Related Device Settings Data when you change your Installed Device by installing Headphones Connect on a new device and or re-installation of the Application and signing in to the same SHES Account.

(ⅱ) Pushing updates to Headphones Connect or your Related Device

Each time you start Headphones Connect on your Installed Device, Headphones Connect sends a “request” to SONY's server to check whether any updates for Headphones Connect or the firmware of the Related Device are available and to send latest software or firmware in case any update should be available. For this, we only use your IP address.

(ⅲ) Providing “Help” upon your request

If Help is requested by you, certain technical information about the Installed Device, about Headphones Connect and about the Related Device are transferred to SONY in order to provide service to you through the Help feature. This transfer of data enables SONY to provide you with “customized” Help webpages for Headphones Connect and the specific technical issue you experience.

(ⅳ) Improving/developing SONY´s products and services

SONY uses the Collected Data to improve and develop SONY’s current and future products and services, which may be linked and analyzed in conjunction with the data we collect through other Sony audio applications if you use one of those. For the collected data through those applications, please refer to the privacy policies for those applications or services. Product improvement and/or development includes those relating to either an improvement of the technical functions of the Related Device or the usability of such product for user´s convenience.

(ⅴ) Marketing strategy and forecast

SONY may use the Collected Data for marketing strategy and forecast, which may be linked and analyzed in conjunction with the data we collect through other Sony audio applications that you may use. For the collected data through those applications, please refer to the privacy policies for those applications.

(B) 360 Spatial Sound Personalizer

Personalized 360 Reality Audio settings service

The 360 Spatial Sound Personalizer enables you to set up customized 360 Reality Audio settings by uploading your 360 Reality Audio settings data to Sony servers and linking to your Headphones Connect Account.

4. Who else has access to the Collected Data?

We do not share personal information with unaffiliated third parties for their own marketing purposes but we may share non-personal information, including aggregate data and de-identified data, with third parties to the fullest extent allowed by law. In addition, SONY may share Collected Data with SONY Affiliates and third parties, as follows:

SONY Affiliates

Collected Data may be shared with and used by SONY Affiliates for the purposes of product improvement and development, which may be linked and analyzed in conjunction with the data we collect through other Sony audio applications that you may use. Collected Data may be also shared with and used by its local operating SONY Affiliates for their marketing strategy and forecast as well. This is only done with information that does not identify you personally, using aggregated and/or anonymized, i.e. non-personal manner. SONY may otherwise share Collected Data with SONY Affiliates for other purposes set out in this Privacy Policy. If you contact your local SONY Affiliates in relation to queries on the Applications, or for repair or return requests of Related Devices we also may need to share Collected Data with that Sony Affiliates in connection with that your request.

Service Providers

SONY and SONY Affiliates may use third party service providers to 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. Our hosting provider is Amazon Web Services in the US, acting as our processor.

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, including any due diligence process connected to the sale or transfer. 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.

Government Authorities/ Law Enforcement Officials

Collected Data may be disclosed to government authorities and/or law enforcement officials if required by the applicable laws.

Other Unaffiliated Third Parties

We 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 we believe necessary to comply with our legal obligations.

Firebase and Apple Push Notifications service

Headphones Connect uses Firebase, a service provided by Google Inc.(“Google”) for Android user, and Apple Push Notifications service, a service provided by Apple Inc.(“Apple”) for iOS user, in order to provide you push notice function. To better understand how Google and Apple use the information it receives, visit:

Google, https://policies.google.com/privacy

Apple, https://www.apple.com/legal/privacy/en-ww/

Baidu Map SDK

If you use the “Learn your frequently visited locations” function, you always need to allow Headphones Connect to use your location permissions. Headphones Connect obtains your GPS data through Baidu Map SDK. You can get more Information regarding how Baidu Map SDK collects, uses and protects your personal information from Baidu Map SDK Privacy Policy(http://lbsyun.baidu.com/index.php?title=open/privacy). You are deemed to have read and agreed to Baidu Map SDK Privacy Policy when you start using the “Learn your frequently visited locations” function.

5. Data Retention

SONY will keep the Collected Data for as long as it is necessary for the relationship with you and the purposes detailed in Section 3 or otherwise permitted or required under applicable law.

SONY may retain Collected Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Collected Data for specific periods.

Where SONY no longer requires the Collected Data, it will be destroyed or de-identified in line with internal SONY information security policies.

6. Transfer of the Collected Data internationally and Consent to processing

The Collected Data may be processed, stored and transferred from your country/regions of residence to countries/regions outside your country/region of residence, including in particular Japan and the United States. 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.

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 information to a third party, such as an overseas authority.

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 absolute 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. 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. 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 information (as defined by applicable law), you should contact us as indicated below.

9. Privacy Rights

In some countries/regions, 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/. 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.

10. Changes/Policy Governs Use

SONY reserves the right to make changes to this Privacy Policy and will notify you of any changes by prominently posting notice of the amendment on or within the Application. We may also provide notice to you in other ways, such as through contact information you have provided. You are advised to consult the posted Privacy Policy regularly for any changes.

Your continued use of the Application after the posted effective date will constitute acceptance of, and agreement to be bound by those changes to the extent allowed by law.

11. Contact Information

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/