Effective Date: This Privacy Policy was revised and is effective as of March 29, 2024.
This Privacy Policy applies to the “Sony | Headphones Connect” (“Headphones Connect”) and “Sony | 360 Spatial Sound Personalizer” (“360 Spatial Sound Personalizer”) applications (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 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. For the purposes of applicable data protection laws and regulations where the concepts of "controller" and “processor” are defined, SONY is the "controller" of the Collected Data described in this Privacy Policy. 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.
SONY collects and uses information or data as described below. Some of this information and data may be considered personal information under applicable law in your jurisdiction. These are 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) (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 (1) a Sony account (SHES Cloud service)
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 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 SHES Account website(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.
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 uses third party services to provide some of the features of Headphones Connect, and collects the following information through those services:
[If your Installed Device is an Android based device]
[If your Installed Device is an iOS based device]
Please note that the above information in this subsection (E) is processed sepa-rately from other Collected Data, and not linked to you, your device or this Application.
In addition to providing you the features/functions of each Application and the related services, SONY uses your Collected Data for the following purposes:
In the event you voluntarily activate this functionality in Headphones Connect, Headphones Connect will 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 data" > "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 use your IP address.
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.
If you activate an Activity function, the Headphones Connect will provide you Activity tracking function based on your activity log with your Related Device.
If you fulfill the requirements to acquire a badge as presented in this function, you will be able to earn the corresponding badge and a log of your acquiring will be sent to SONY.
In addition, SONY processes content information regarding details of the content you listened to with the Related Device in order to provide you with your listening history, and use profile when you activate “Listening History” as a part of Activity function. If you wish to disable the “Listening History” function, go to "Activity" > "(3 dots) Menu" > "Activity Settings" > "Record Activity" in Headphones Connect.
Except for the above, 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.
If you would like to delete information regarding your "Activity" on the Installed Device, you can go to “Activity” > “(3 dots) Menu” > “Activity Settings” > “Initialize Activity”.
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 products and applications if you use one of those. For the collected data through those products and applications, please refer to the privacy policies for those products 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 use Collected Data to ask you whether you would like to participate in one of our surveys regarding our products and services. You can decide not to participate in the survey by closing the browser or tabs of the survey at any point during the survey.
Subject to your consent, SONY may use Collected Data (except data collected solely for backup and restoration service, and customer demographic/attribute information obtained through Firebase) to create inferences and develop profiles about you and share the data with its local SONY electronics company which may send you emails and provide you with information, recommendations and targeted and/or personalized advertisements and marketing regarding 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 SONY electronics company, please refer to the respective privacy policy. For users in the United States, click here: Sony Electronics Privacy Policy and for California residents: and for California residents:Calif. Privacy Notice
For users in Canada, click here: EN) Sony Canada Privacy Policy, FR) Sony.ca Code de protection de la vie privée
You can unsubscribe from receiving email marketing from the local Sony electronics company 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 disable data use and sharing with the local Sony electronics company for marketing, please ensure that the setting for “Data use for marketing and product/service improvement purpose” in the [Privacy setting] in [About this app] is disabled.
To the extent permitted by law, the local SONY electronics company may share Collected Data with its advertising partners 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 disabling your advertising ID on your device. 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.
If you accept the respective [Terms of Use], 360 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.
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:
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 products or applications if you use any of those. SONY may otherwise share Collected Data with SONY Affiliates to provide services on our behalf as 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.
SONY and SONY Affiliates may use third party service providers to process the Collected Data on our 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. We may also disclose the Collected Data to third party analytics services, such as Google’s Google Analytics.
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.
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 as we believe necessary to comply with our legal obligations.
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/
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.
The Collected Data may be processed, stored and transferred to countries/regions outside your country/region of residence, including in particular the United States, Japan and across Canada. By using the Application(s), 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, across Canada 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. Further, courts, law enforcement, and other authorities in countries/regions outside your residence may be entitled to access Collected Data upon its transfer.
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(s) 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. The 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.
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.
If you have any questions or comments about our practices regarding your Collected Data 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 ULC,
Attn: Privacy Officer, Law Department
2235 Sheppard Avenue East, Suite 800 Toronto, ON M2J 5B5
Telephone, toll-free (within Canada): 1-888-494-7669
Email: privacy@am.sony.com
In some jurisdictions, you may have certain rights with respect to the Collected Data that SONY holds about you. These may include the right to request access to the Collected Data and/or you may request that SONY corrects, amends, deletes, erases, destroys, blocks/restrict processing and/or use of such Collected Data. You may also object to Sony’s processing of Collected Data. 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 rights available to you, please contact us as described in Section 9. Contact Us.
We set forth in our Privacy Policy, Table 1 and Table 2the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
Consumers in certain states with comprehensive privacy laws may have the following rights:
Right to Know: the right to confirm whether we are processing personal data about you.
Right to Correct: the right to correct inaccurate Personal Data we hold about you.
Right to Delete: the right to delete the Personal Data provided by you or obtained about you.
Right to Access and Data Portability: the right to access your personal data and obtain a copy of the Personal Data previously collected by us and, to the extent feasible, in a readily usable format to allow data portability.
Right to Appeal: If for any reason you would like to appeal a decision made by us relating to your request to exercise privacy rights, you have the right to submit an appeal to us. Please include your full name, the basis for your appeal, and any additional information to consider.
If you would like to submit a request to exercise one of the rights listed above, you can do so by completing this form: Data Requests
Right to Opt-Out of Targeted Advertising: Your local Sony electronics company may engage in online advertising and analytics practices that may be considered “targeted advertising” or a “sale” of data under applicable state law.
To exercise your rights to opt-out targeted advertising, please ensure that the setting for “Data use for marketing and product/service improvement purpose” in the [Privacy setting] in [About this app] is disabled.
You may also submit a request here: Opt-out of Targeting Advertising
Right to Opt-Out of Profiling or Sale of Personal Information: While state laws may permit you to opt-out of the sale of your Personal Data and out of profiling in furtherance of decisions that produce legal or similarly significant effects, we do not engage in either of these activities at this time.
This California Privacy Notice is effective as of [October 18, 2023].
This California Privacy Notice supplements our Privacy Policy sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Privacy Rights Act, as amended, and any implementing regulations adopted thereunder (“CPRA”). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.
California Consumer Rights. Subject to certain exceptions, as a California consumer, you may have the following rights regarding your Personal Information:
Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under applicable state law. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We will only use the information you provide in a request to verify your identity.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify your identity, we will not be able to process the request.
Exercising Your Rights.
Right to Know; Right to Delete; Right to Correct
If you are a California Consumer and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please submit your request at: Data Requests; or you may call us toll-free at 1-833-681-9900.
Do Not Sell or Share for Cross Context Behavioral Advertising
Right to Opt-Out of Sale/Sharing
To opt-out of the “sale” or sharing of your personal information for cross-contextual behavioral advertising, please ensure that the setting for “Data use for marketing and product/service improvement purpose” in the [Privacy settings] in the [About this app] menu of the Applications is disabled, and also submit a request at: Do Not Sell/Share My Personal Information
Limit the Use of My Sensitive Personal Information: To exercise your right to limit the use of your sensitive personal information, please ensure that the setting for “Data use for marketing and product/service improvement purpose” in the [Privacy settings] in the [About this app] menu of the Applications is disabled.
Data Retention. Sony retains data for as long as necessary for the purposes outlined in this California Privacy Notice.In particular, we retain your personal information when you have an account with us, or as long as you use the Application.Sony either deletes your Personal Information or de-identifies it after as long as it is necessary for the relationship with you and the purposes de-tailed in Section 2, except as required or permitted by law.
Data Reporting
Click here to access our data reporting metrics for the previous calendar year.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will not discriminate against you for exercising your CPRA rights.
Notice of Financial Incentive
Under California regulations, if we offer certain loyalty or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a “financial incentive”. In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.
Personal Information We Collect & Purposes for Collection
The Personal Information we collect about you will depend upon how you use the Application(s). Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by applicable law.
We may have used Personal Information for the business or commercial purposes described in Table 1 and Table 2:
[Table 1] Headphones Connect
| Categories of Personal Information Collected | Purposes for Collection of Personal Information | Who We Share Personal Information With for a Business Purpose | Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising |
|---|---|---|---|
| Identifiers: Such as: Email address; your name, postal code, online identifier such as IP address; Device ID, Android Advertising ID, Identifier for Advertisers |
•Provide account service •Backup and Restoration of Settings service •Pushing updates to Headphones Connect or your Related Devices •Providing “Help” upon your request •Providing “Activity” function •Improving/developing SONY´s products and services •To provide you with information and advertisements •Compliance with law •Exercising legal rights |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Business transfer recipients •Customer service providers •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
| Electronics and Network Information: Such as: usage status and usage history of Application, Installed Device and Related Devices |
•Backup and Restoration of Settings service •Providing “Help” upon your request •Providing “Activity” function •Improving/developing SONY´s products and services •To provide you with information and advertisements •Compliance with law •Exercising legal rights |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Customer service providers •Business transfer recipients •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
| Sensitive Information Such as: any inferences based on content you listen to that may be considered sensitive |
•To provide features of the Application •For product and service development •To provide you with information and advertisements |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Business transfer recipients •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
| Inferences Drawn from Other Information and Consumer Characteristics: These may relate to demographics (e.g., gender, age, region/general location), interests or hobbies, and inferences drawn from collected information. |
•Backup and Restoration of Settings service •Providing “Help” upon your request •Improving/developing SONY´s products and services •To provide you with information and advertisements •Compliance with law •Exercising legal rights |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Business transfer recipients •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
[Table 2] 360 Spatial Sound Personalizer
| Categories of Personal Information Collected | Purposes for Collection of Personal Information | Who We Share Personal Information With for a Business Purpose | Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising |
|---|---|---|---|
| Identifiers: Such as: Email address; your name, postal code, online identifier such as IP address; Device ID, Android Advertising ID, Identifier for Advertisers |
•Personalized 360 Reality Audio settings service •Compliance with law •Exercising legal rights |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Business transfer recipients •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
| Electronics and Network Information: Such as: usage status and usage history of Application and Related Devices |
•Personalized 360 Reality Audio settings service •Compliance with law •Exercising legal rights |
•SONY Affiliates •IT Service Providers •Hosting Service Providers •Business transfer recipients •Government Authorities/ Law Enforcement Officials •Auditors and external consultants (e.g. lawyers, tax accountants) |
Third party ad vendors via our local operating company |
For more information about our local Sony electronics affiliate’s California privacy practices, please refer to this California-specific information here: Calif. Privacy Notice
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 and 360 Spatial Sound Personalizer.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
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 360 Spatial Sound Personalizer.” 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.
This notice sets forth disclosures and rights for consumers residing in Québec, Canada regarding their personal information, as required by the Québec’s Data Privacy Law 25. All Sony personnel handling personal information will be subject to a duty of confidentiality and to ensure that all personal information is handled in accordance with standard security measures. By using the Application, you acknowledge and agree that your personal information will be transferred outside of Quebec.
We will only use your personal information for the purposes stated at the point of col-lection, or as otherwise noted in this privacy policy.
Profiling: We may use personal information for profiling. “Profiling” means the collection and use of personal information to assess certain characteristics of a natural person, in particular for the purpose of analyzing that person’s work performance, economic situation, health, personal preferences, interests or behavior. It is possible to opt-out of profiling by withdrawing your consent to our use of your data by disabling the setting for "Data use for marketing and product/service improvement purpose” in the [Privacy settings] in the [About this app] menu of the Applications and disabling the Listening History function by going to "Activity" > "(3 dots) Menu" > "Activity Settings" > " Record Activity" in Headphones Connect.
Location Tracking: We may use technologies which collect information about your general location, such as your country. However, we will not track your location without your consent.
Consumer Rights:
Subject to certain exceptions, you may have the following rights regarding your personal information:
Exercising your rights: If you are a Quebec resident and wish to exercise your right(s) listed above, please submit your request here: SOCAN Privacy Request Webform; or you may call our toll-free (within Canada) number 1-888-494-7669.
Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regard-ing this request.
Our Privacy Officer is in charge of the protection of personal information.
Contact information for Sony’s Privacy Officer:
Sony of Canada ULC,
Attn: Privacy Officer, Law Department
2235 Sheppard Avenue East, Suite 800 Toronto, ON M2J 5B5
Telephone, toll-free (within Canada): 1-888-494-7669
Email:
You may submit a complaint to the Commision d’accès à l’information du Québec (CAI) by visiting:
https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.