Effective Date: This Privacy Policy was revised and is effective as of May 19, 2022.
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”). This Privacy Policy explains how we use what types of your personal data, with whom we share the data, how we transfer it to other countries/regions, how long we keep the data, what rights and choices you have and how you can contact us with queries 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
This Privacy Policy only applies to the Application 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.
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”).
If you decide to activate certain services, such as the Backup and Restoration of Settings service described in section 3. (A) (ii) , 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 either (1) a Sony account (SHES Cloud service) or (2) a Google, Facebook, Amazon or Apple (“ID provider”) authentication.
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.
If you choose to create or use a Sony account (SHES Cloud service) for authentication when you create a SHES Account, SONY will collect the following:
We also collect information about your usage of the website of the SHES Account (access status, etc)
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.
If you choose to use an ID provider authentication when you create a SHES Account, SONY will collect the following:
Please note that the information we collect from and through an ID provider may depend on the privacy settings you have set with the ID provider and the permissions you grant to us in connection with linking your SHES Account to your account with an ID provider. We do not share any Collected Data with the ID provider, and the personal information an ID provider has about you is obtained by the ID provider independent of our service, and SHES is not responsible for it.
For more information how relevant ID provider handles the processing of your data, please visit the following websites:
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.
If you would like to know more about the processing of information above, please refer to the SHES Account Privacy Policy.
From time to time, SONY may ask you whether you would like to participate in one of our surveys. We may ask for information, such as your interests and preferences with regard to current and future products and services on the market.
You can decide not to participate in the survey by closing the browser or tabs of the survey at any point during the survey.
SONY may collect information about your ear through photos you take and incorporate in the Application. When you provide photos of your ear, SONY will extract and analyze features of your ear and use them only for the purposes of optimizing acoustic characteristics of spatial sound, such as 360 Reality Audio. SONY deletes the photos immediately after such extraction and analysis.
Operating System and Operating System version;
Operational status of your Installed Device and component parts thereof (e.g. sensors and display); and
IP address used by such Installed Device’s internet connection.
Application version; and
Information regarding the usage status and usage history.
SONY may collect information about your ear through photos you take and incorporate in the Application. When you provide photos of your ear, SONY will extract and analyze features of your ear and use them only for the purposes of optimizing acoustic characteristics of spatial sound, such as 360 Reality Audio. SONY deletes the photos immediately after such extraction and analysis.
In order to provide you with 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 (“Related Device Settings Data”) and link this information with your respective SHES Account.
Related Device Settings Data includes the following information
SONY processes your Collected Data through the Application for the purposes listed hereafter:
SONY processes none of the Collected Data to provide or operate the minimum functions of Headphones Connect. These basic activities happen on the Installed Device´s operating system. For this, no Collected Data is transferred to SONY.
In the event you voluntarily activate this functionality in Headphones Connect, Headphones Connect provides a backup and restoration of settings function linked with your SHES Account, whereby the Related Device Settings Data are 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 or re-installation the Application and signing in to the same SHES Account.
Please note that the legal basis under EU-law for SONY processing your Related Device Settings Data for Backup and restoration of settings is Article 6 (1) (b) General Data Protection Regulation.
If you would like to delete the Related Device Settings Data, you can go to [Backup and restoration of settings and records] > [Delete the backup and sign out].
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 process your IP address.
Please note that the legal basis under EU-law for SONY processing your IP address data for pushing updates to your Headphones Connect or Related Device is Article 6 (1) (b) General Data Protection Regulation, the necessary of performance of the EULAwe have with you.
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. For this, we process the following Collected Data:
Please note that the legal basis under the EU-law for SONY processing Collected Data for providing “Help” upon your request is that such processing is for services and support provided Article 6 (1) (b) General Data Protection Regulation and in the other cases Article 6 (1) (f) General Data Protection Regulation, the necessary for the purposes of our legitimate interests pursued by Sony. The legitimate interest pursued by SONY in relation to our use of your Collected Data is the efficient and effective provision of support to our customers.
If you activate a function, Headphones Connect will provide you Activity tracking function based on your activity log with your Related Device.
SONY processes none of the Collected Data to provide the Activity function of the Headphones Connect for operating it. This happens on the Installed Device. For this, no Collected Data is transferred to SONY.
If you would like to delete information regarding your Activity on Installed Device, you can go to [Activity Settings].
SONY uses the Collected Data (except data collected solely for backup and restoration service) listed in Section 2 (B) and (C) above to improve and develop SONY’s current and future products and services where you select “OPT IN to help improve products and 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. Such product improvement/development is only done on a “general” level, not on an individual user level, so specific users are not targeted. This includes through analyzing log-files of the app usage.
SONY may for this purpose ask you whether you would like to participate in one of our surveys by using Collected Data. You can decide not to participate in the survey by closing the browser or tabs of the survey at any point during the survey.
Please note that your consent forms the legal basis for SONY processing Collected Data for improving/developing SONY’s products and services under EU-law (Article 6 (1) (a) General Data Protection Regulation).
In this case, we process the Collected Data listed in Sections 2 (B) and (C) above 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 Headphones Connect.
SONY shares the Collected Data (except data collected solely for backup and restora-tion service) with Sony Europe BV for the following purposes.
If you select "OPT IN to get Sony news and recommendations via display ads“, Sony Corporation will share with Sony Europe B.V. your personal data in connection with your SONY headphones as described in section 2 (B) (i), (ii) and (iii) above (including your digital identifiers) to provide you with general information, recommendations ad-vertisements, and marketing regarding Sony products, services and other offerings that may be of interest to you. Such advertising may be delivered to you across Sony and third party websites and social networks that you visit and Sony and thirds party apps which you use.
If you select "OPT IN to get tailored information“ or “OPT IN to get Sony tailored news and recommendations”, Sony Corporation in Japan will collect and then share with Sony Europe BV (EU) your personal data as described in section 2 (A) (only when you give additional consent in SHES Account you create) and (B) (i), (ii) and (iii) above (including your digital identifiers). Subsequently, Sony Europe BV will personal-ise or tailor the messages sent to you so that you can receive new product infor-mation, articles, offers and promotions, or support information that are tailored to your interests and needs. You may notice this personalisation and targeting when you use Sony products and services, when Sony Europe BV contacts you with marketing communications (including email when you give additional consent to receive email marketing in SHES Account you create) and when you visit Sony and third party web-sites or apps, social networks and services that show advertisements from SONY or our advertising partners (for example, you might see an advertisement relevant to a product that you have recently used).
Sony Corporation or Sony Europe BV will for this purpose evaluate your preferences and interests based on your personal data above through profiling.
With your consent (in SHES Account and My Sony ID) Sony Europe BV may also provide you with personalized or tailored marketing via email. For more information, please refer to the Privacy Policy of SHES Account.
Please note that your consent forms the legal basis for SONY to collect and share Col-lected Data with Sony Europe BV to provide you with information and advertisements under EU-law (Article 6 (1) (a) General Data Protection Regulation).
You can withdraw your consent above at any time by selecting "(3 dots) Menu" > "About this app" > "Privacy settings" in the Headphones Connect.”
SONY processes none of the Collected Data to provide or operate the minimum functions of the 360 Spatial Sound Personalizer. These activities happen on the Installed Device's operating system. For this, no Collected Data is transferred to SONY.
If you accept the respective [Terms of Use], the Spatial Sound Personalizer provides a personalized 360 Reality Audio settings service linked with your SHES Account, whereby the Related Device Settings Data are uploaded to and stored on our servers.
Please note that the legal basis under EU-law for SONY processing your Related Device Settings Data for Backup and restoration of settings is Article 6 (1) (b) General Data Protection Regulation.
We do not share Collected Data with third parties for their own marketing purposes. 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:
The Collected Data may be shared with and used by Sony Europe BV as an independent controller for the purposes of “Sharing the Collect-ed Data with Sony Europe BV to provide you with information and advertisements” (Section 3 (A) (vii)). If you contact Sony Europe BV in relation to queries on the Applications, or for repair or return requests of Related Devices, we may also need to share Collected Data with Sony Europe BV in connection with that your requests.
SONY and Sony Europe BV may use Sony Global Solutions in Japan and other third party contractors as processors/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 or data hosting providers. Our hosting provider is Amazon Web Services in the US, acting as our processor.
In the event that SONY or Sony Europe BV sells or transfers a portion or all of its business, the Collected Data may be transferred by SONY or Sony Europe BV to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer.
Collected Data may be disclosed to government authorities and/or law enforcement officials if required by the applicable laws.
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 to help us fulfill our legal obligations.
Headphones Connect uses Firebase, a service provided by Google Inc.(“Google”) for Android users, 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/
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.
With regard to Collected Data which is processed based on your consent declaration, SONY will apply a maximum of twenty-seven (27) months retention period from the date of the collection of the Collected Data.
Collected Data which is processed for pushing updates to the Application or Related Device will be deleted after the Internet communication required for this is completed.
Collected Data which is processed for providing Help to you upon your request will be deleted after the requested Help has been provided to you.
Collected Data which is processed for the Backup and restoration of settings function will be deleted either if you delete your backup within the Application or automatically if we terminate the Backup and restoration of settings function in accordance with the [Terms of Use].
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.
Where information is transferred out of the European Economic Area (EEA) to us or a third party in connection with the purposes set out in this Privacy Policy, we will, to the extent that no statutory level of security comparable to the European data protection laws exists in such countries/regions, adopt appropriate measures to ensure that your personal data will be adequately protected in these countries/regions. In particular, we may apply the standard contractual clauses published by the European Commission, which can be accessed here. Where the Collected Data is transferred to Japan, the adequate level of data protection is confirmed by the European Commission´s adequacy decision.
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.
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. This Application is intended for a general audience; the Application is not directed to and does not knowingly collect personal information from children younger than age 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 a SONY and SONY Affiliate with personal information (as defined by applicable law), you should contact such SONY Affiliate as indicated below.
In some countries/regions, you have certain rights with respect to the Collected Data SONY or Sony Europe BV holds about you. These may include the right to request a copy of the Collected Data that SONY or Sony Europe BV holds about you and/or the right to request that SONY or Sony Europe BV 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).
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/hpc_pp_index.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.
This Privacy Policy applies to: SONY as a data controller. 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 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 or Switzerland:
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 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 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 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.
With regard to your Collected Data that we process if you are located in the EU/EEA, UK or Switzerland, you may have the following rights (pursuant to Art. 15-18 and Art. 19-21 GDPR, if you are located in the EEA):
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 SONY at www.sony.net/SonyInfo/Support/
You also have the right to lodge a complaint to a supervisory authority for data protection (Art. 77(1) GDPR) 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.