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 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:

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:

Login with Amazon
Sign in with Apple
Facebook Connect: Privacy Policy and Terms of Use
Google: Privacy policy and Terms of Use;

(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) Providing information and advertisements to you through Affiliates

SONY shares the Collected Data with its local operating SONY Affiliate which may send you emails and provide you with information, recommendations and targeted and/or personalized advertisements and marketing regarding Sony products, services and other offerings that may be of interest to you. Such advertising may be delivered to you directly or across websites that you visit. For more information on the privacy practices of our local operating SONY Affiliates, please refer to the respective privacy policy. For users in the United States, click here: Sony Electronics Privacy Policy and for California residents:CA Privacy Notice

For users in Canada, click here: EN) Sony Canada Privacy Policy, FR) Sony Canada Privacy Policy

You can unsubscribe from receiving email marketing from Sony Affiliates at any time using the “unsubscribe” link in such email or you may contact such Sony Affiliate as described in the applicable privacy policy.

To the extent permitted by law, SONY Affiliates may share de-identified Collected Data with network advertisers or others in order to target advertisements to you or limit the number of times you see advertisements. You may be able to opt out of certain targeted advertising by visiting TRUSTe's website here. Please be aware that if you choose to block cookies, some advertising preferences dependent on cookies may not be able to be respected and that even if you opt out of targeted online advertising, you will continue to receive generic ads online.

(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 setting data to Sony servers and linking to your SHES 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

The Collected Data may be shared with and used by SONY Affiliates for internal business purposes and for product and service improvement and development, which may be linked and analyzed in conjunction with the data we collect through other Sony audio applications if you use one of those. SONY may otherwise share Collected Data with SONY Affiliates for other purposes set out in this Privacy Policy. If you contact your local SONY Affiliate 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 Affiliate in connection with that 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.

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/

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.

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

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

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. 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 younger than 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. 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.

10. Notice to California Residents/Other State Rights:

California Privacy Notice

If you reside in California, we are required to provide additional information to you about how we collect, use and disclose your information, and you have the right to request that we provide you with access to Collected Data, delete Collected Data, and to opt-out of any sale of personal information. Please refer to this California-specific information here:CA Privacy Notice

California residents may submit a data request here:
Do Not Sell My Info
Data Access/Deletion Requests

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 company(ies) 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 – Headphones Connect.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.

Notice to Nevada Residents:

If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. SONY does not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if Sony were to engage in such a sale in the future, you may submit your request in writing to: privacy@am.sony.com. Your request must reference “Your Nevada Rights – Headphones Connect” and include your name, mailing address, zip code, and email address. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. We will respond to valid requests within 60 days.

11. Contact Us

If you have any questions or comments about our practices regarding your Collected Information or about this Privacy Policy, please contact us at:

United States:
Sony Electronics Inc.
115 West Century Rd., Suite 250
Paramus, NJ 07652
Attn: Privacy Office

Telephone: 1-833-681-9900
Email: privacy@am.sony.com

Canada:
Sony of Canada Ltd.,
Attn: Privacy Officer, Law Department
2235 Shepard Avenue East, Suite 700 Toronto, ON M2J 5B5

Telephone, toll-free (within Canada): 1-888-494-7669
Email:privacy@am.sony.com