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 13, 2023.


This Privacy Policy applies to the “Sony | Headphones Connect” (“Headphones Connect”) and “Sony | 360 Spatial Sound Personalizer” (“360 Spatial Sound Personalizer”) applications (collectively referred to as 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 preferences.

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(s) (collectively referred to as the “Collected Data”).

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

(i) Before 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) an authentication by Google LLC. (“Google”), Facebook, Inc., Amazon.com, Inc., or Apple, Inc. (“Apple”) (collectively referred to as “ID provider”).

More information about the data we collect in connection with each authentication method is below.

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 SONY 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) After sign-in authentication

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.

(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) which are detected by or registered to Headphones Connect (“Related Device”):

(ⅳ) Information collected by surveys:

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.

(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:

(D) 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 (“Related Device Settings Data”) and link this information with your respective SHES Account.

Related Device Settings Data includes following information.

3. How does SONY use the Collected Data?

SONY uses your Collected Data for the following purposes:

(A) Headphones Connect

(i) Providing the minimum functions of the Headphones Connect

SONY processes none of the Collected Data to provide or operate the minimum functions of the Headphones Connect for operating it. These basic activities happen on the Installed Device´s operating system. For this, no Collected Data is transferred to SONY.

(ⅱ) Backup and Restoration of Settings service

In the event you voluntarily activate this functionality in the Headphones Connect, 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.

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].

(ⅲ) 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.

(ⅳ) 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 is 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.

(ⅴ) Providing “Activity” function

If you activate an Activity 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 or operate the Activity function of the Headphones Connect. 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].

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

SONY uses the Collected Data (except data collected solely for backup and restoration service) 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 improvements of the technical functions of the Related Device and the usability of SONY’s products and services.

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.

(ⅶ) 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.

(ⅷ) Sharing the Collected Data with Sony Affiliates to Provide you with information and advertisements (where you have opted in)

If you reside in Australia, Hong Kong, India or Taiwan , SONY shares the Collected Data (except data collected solely for backup and restoration service) with your local Sony Affiliate, (namely Sony Australia Limited, Sony Corporation of Hong Kong Limited, Sony India Private Limited and Sony Taiwan Limited (collectively referred to as “SONY APAC Marketing Entities”)), if you have given consent by opting in to receiving information, recommendations and targeted and/or personalized advertisements and marketing communications regarding Sony products, services and other offerings that may be of interest to you (“Marketing Communications”) from your local SONY APAC Marketing Entity. These Marketing Communications may be delivered to you directly or across websites that you visit. You may opt out of receiving these Marketing Communications from your local SONY APAC Marketing Entity at any time. For more information on the privacy practices of the SONY APAC Marketing Entities, please refer to:

Sony Australia Limited

Sony Corporation of Hong Kong Limited

Sony India Private Limited

Sony Taiwan Limited

(B) 360 Spatial Sound Personalizer

(i) Providing the minimum functions of the Spatial Sound Personalizer

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.

(ⅱ) 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 SHES Account.

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.

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 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. The Collected Data may be also shared with and used by its local 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. Furthermore, if you reside in Australia, Hong Kong, India or Taiwan, the Collected Data may be shared with SONY APAC Marketing Entities for targeted and/or personalized advertisements if you have given consent by opting in to receive such marketing communications (Section 3 (A) (vii)). 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 Cloud Messaging and Apple Push Notifications service

Headphones Connect uses Firebase Cloud Messaging, a service provided by Google for Android user, and Apple Push Notifications service, a service provided by 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.

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(s) are intended for a general audience; the Application(s) are not directed to and do not knowingly collect personal information from children younger than 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(s). 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(s) after the posted effective date will constitute acceptance of, and agreement to be bound by those changes to the extent allowed by law.

11. Additional Notice

[For Residents in Asia & Oceania regions]

Please read this Privacy Policy carefully because by using this Application, you will be deemed to have agreed and consented to the terms of this Privacy Policy.

By agreeing to this Privacy Policy and by using the Application, you agree that you will not hold SONY or SONY Affiliates liable to any complaints or damages whatsoever relating to the processing of the Collected Data by an acquiring entity in the event a business transfer as described in Section 4. of this Privacy Policy takes place.

12. 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/

FOR RESIDENTS IN KOREA

Sony Corporation, would designate a domestic representation according to Korea local regulation as following.

Name: Sony Korea Corporation (representative director:Okura Kikuo)
Address: 24F, One IFC, 10 Gukjegeumyung-Ro, Yeongdeungpo-Gu, Seoul, Korea
Contact information: 02-1588-0911/sokprivacy@sony.co.kr

FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:

If you have any concerns about how we process your data, you can find our contact details below or on the website of your local Sony Affiliates at:

For Mexico, Central and South America and the Caribbean:

Regional Latin America Privacy Office at https://www.sony-latin.com/corporate/SOLA/home.html

Africa and Middle East: https://www.sony-mea.com/en/locale-selector

Asia & Oceania: http://www.sony-asia.com/countryselector.html