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 the Wireless Headphones from SONY. It allows you to customize the sound from your headphones according to your preference.
In this Privacy Policy, we use or "we," "us," and "our" to refer to Sony Video & Sound Products Inc. “SONY Affiliate” shall mean any legal entities controlled by Sony Corporation, which is the ultimate parent company of SONY. SONY and SONY Affiliate shall be collectively referred to as “SONY Group”.
1. SUMMARY OF KEY POINTS
- We use your Personal Information (defined below) to provide you with features and functions of Sony | Headphones Connect Application, and to provide you with other requested content related to our services and other offerings. Click here to learn more.
- The Privacy Policy also describes your data protection rights, including a right to object to some of the processing which Sony carries out. Click here to learn more about your rights.
- We disclose Personal Information when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Click here to learn more.
- We may transfer your Personal Information to the United States, Japan and other jurisdictions that may not provide the same level of data protection as your home country. Click here to learn more.
2. What Information do we obtain about you?
SONY use your personal data as follows below and consolidate various information about you and your interactions (collectively, the “Personal Information”) collected automatically when you use the Application.
(i) Information about your device on which the Application is installed and component parts thereof:
- - device ID which is to be allocated automatically, Google Advertising ID (if you use an Android based device), product type, manufacturer name, and model name;
- - Operating System and Operating System version;
- - language code, country or region, time zone; and
- - operational status of your device and component part (e.g. sensors and display) thereof;
(ii) Information about the Application:
- - application ID;
- - application version;
- - information regarding contents operated or managed via the Application;
- - time stamp related to the usage of the Application; and
- - information regarding the usage status and usage history of the Application
(iii) Information about the device to which the Application is connected or which is detected by the software (namely, your audio product, router, media server and media renderer):
- - device ID, serial number, model name, manufacturer name and firmware version; and
- - device name which you registered
(iv) Information of the composition related to the device, the Application, contents of the Application, the device to which the Application is connected or which is detected by the Application software and excluded software;
(v) Information regarding how you are using the device, the Application, contents of the Application the device to which the Application is connected or which is detected by the software and excluded software, for example:
- - when you use them; how often you use them; which functions you use; or related statistical information; and
(vi) IP address.
The Personal Information collected automatically described above will be uploaded with a unique number assigned to the devices the Application is installed on and will allow SONY Group to distinguish the data received from the device from those received from other devices.
Sony use the above Personal Information as it is necessary to fulfil the contract and provide you with the features and functions of the Application. If you oppose to SONY's use of Personal Information, you may not be able to use all features and functions.
Please be aware that neither the Personal Information sent to SONY nor the recommendations provided via the Application are filtered and they may refer to potentially sensitive programs (such as adult content) if watched.
3. How does SONY use your Information?
We use Personal Information listed in Section 2 collected through the Application:
(i) To fulfil a contract, that is to provide you with the features and functions of the Application.
(ii) Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:
- - To improve and develop SONY’s and SONY Group’s current and future products and services
- - To identify potential security threats and to protect SONY, SONY Group and its users against data leaks of data stored in servers or systems, system breakdown effects or unauthorized access to data stored in servers or systems.
- - In response to requests by government or law enforcement authorities conducting an investigation
- - To send you information you have requested
- - To enforce compliance with our terms of use and other policies and to help other organizations (such as copyright owners) to enforce their rights
- - To assess your preference please see Section 4 for more details.
(iii) For purposes which are required by law:
- - In response to requests by government or law enforcement authorities conducting an investigation.
4. Assessing your preferences
To improve services we provide you, we use Personal Information to create a profile of you, including your interests, behavior related to the Application and information on our services you have used. This Personal Information collected automatically, described above in the Section 2, is used for statistical purposes and offers users tailored content – such as giving you information regarding how to use the Application or headphones connecting with the Application. In order to serve tailored service, users of the Application may be profiled such as by assigning them into categories (profiles) by assuming various characteristics about them. Assigning you to a certain category enables us to predict your future expectations towards our products and suggest products that suit your needs best. Using our services you will not be subject to solely automated decision making which produces legal effects concerning you or similarly significantly affects you.
5. Who else has access to your Personal Information?
Your Personal Information that is communicated to and stored by SONY may be made available to SONY Affiliate and to other third parties, as follows:
SONY Affiliate
Your Personal Information may be shared with and used by other SONY Affiliate for the purposes of pursuing the activities outlined in the Section 3 above.
Third party contractors
SONY and SONY Affiliate may use third party contractors to process or analyze your Personal Information on SONY's behalf for the purposes set out in this Privacy Policy.
Business transfer
In the event that SONY or SONY Affiliate sells or transfers a portion or all of its business, your information 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 your Personal Information as required or permitted by law, regulation or order, 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.
6. Data Retention
SONY will collect the Personal Information described in Section 2 for as long as you use the Application and such collected Personal Information 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 Personal Information by law.
7. Transfer of your Personal Information internationally
The Application is available to users around the world. Your Personal Information will be processed, stored and transferred for the purposes outlined in Section 3 to countries outside the European Economic Area (EEA) and/or your country of residence, including in particular Japan and the United States. Your Personal Information will be processed by staffs operating outside the EEA and/or your country 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. As Personal Information about you will be transferred to and processed in countries outside the EEA, where the privacy laws may not provide an equivalent level of protection to those in your home country, we use Standard Contract Clauses approved by the European Commission to protect Personal Information about you. If you have questions or concerns about SONY's data transfer arrangements, please contact us, using the contact information set out later.
8. Security
SONY undertakes reasonable security measures designed to protect against the loss, misuse or alteration of your Personal Information. Although SONY strives to protect your Personal Information, SONY cannot guarantee or warrant the security of any Personal Information transmitted to SONY through the Application or that SONY stores on its systems or that is stored on SONY’s third party contractors' systems.
9. SONY’s Policy Regarding Children
SONY Group is committed to complying with all applicable laws and regulations regarding the collection, storage and use of Personal Information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries. If you are a parent or guardian and are concerned that your child has provided a SONY Affiliate with Personal Information without your consent, you should contact such SONY or SONY Affiliate as indicated below.
10. Privacy Rights (including California Privacy Rights and EU data protection rights)
In some countries, including countries in the EEA, you have certain rights with respect to the Personal Information SONY or SONY Affiliate holds about you. These may include the right to request a copy of the Personal information that SONY or SONY Affiliate holds about you and/or you may request that SONY or SONY Affiliate corrects, amends, deletes or blocks/restrict such Personal information if it is inaccurate. You may also ask us to provide some types of Personal Information to you, or another organization nominated by you, in a structured and machine readable format. In addition, you can object to the processing of your Personal Information 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 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 Personal Information.
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
11. 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/eula-pp/eula_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.
12. Contact Information
This Privacy Policy applies to: SONY as a data controller according to applicable EU law. SONY's address is Sony City Osaki, 2-10-1, Osaki, Shinagawa-ku, Tokyo, 141-8610, Japan.
(For European Users) Sony has appointed Sony Europe Limited, of The Heights, Brooklands, Weybridge, Surrey, KT13 0XW, UK as its EU representative for the purposes of the GDPR.
privacyoffice.seu@sony.com
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 your Personal Information, please contact us at
www.sony.net/SonyInfo/Support/
Effective Date: This Privacy Policy is effective as of September 3, 2018.
© 2017, 2018 Sony Video & Sound Products Inc.