Article ID : 00223358 / Last Modified : 07/29/2020

"Support by Sony" Privacy Policy

    This Privacy Policy applies to "Support by Sony" (the "Application"). The Application allows you to access various support information about your Sony products. You can get the most out of your product by receiving firmware update notifications, and viewing various support materials including manuals and Q&A.

    In this Privacy Policy, we use "SONY," "we," "us," and "our" to refer to Sony Marketing Inc. 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.

    1. Summary of Key Points

    • We use the Collected Data (defined below) to provide you with features and functions of "Support by Sony" Application, and to provide you with other requested content related to our services and other offerings. Learn more about Collected Data usage.
    • The Privacy Policy also describes your data protection rights, including a right to object to some of the processing which SONY carries out. Learn more about your data protection rights.
    • We disclose the Collected Data when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Learn more about Collected Data disclosure.
    • Depending on where you are located, the Collected Data may be transferred out of your home country/region to the United States, Japan and other jurisdictions that may not provide the same level of data protection as your home country/region. Learn more about Collected Data transfer.
    • Philippine Citizens/Residents, please see 13. Additional Notice for more information.

    2. Information collected when you use Support by Sony

    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 (collectively, the "Collected Data") and it is collected automatically when you use the Application.

    (i) Information about your device on which the Application is installed (the "Installed Device"):

    • Device ID, model name, name of manufacturer
    • Operating System and Operating System version
    • Language code, country or region, time zone

    (ii) Information about the Application:

    • Application information (application ID, application version)
    • Information regarding the usage status and usage history of the Application on the Installed Device

    (iii) Your information on the Support by Sony Application:

    • Information about products that you want to receive update notifications of firmware, "Target Model" (model name, purchase date)
    • Setting information regarding receiving update notifications

    Information collected automatically described above will be uploaded with Device ID, a unique number assigned to the devices the Application is installed, which allows us to distinguish the data received from such device from that received from other devices.

    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 the Application.

    3. How does SONY use your information?

    SONY processes your Collected Data through the Application for the purposes listed hereafter:

    (For the avoidance of doubt, SONY does not process any of the Collected Data to provide such minimum functions of the Application as receiving firmware update notifications, and viewing various support materials including manuals and Q&A. These activities happen on the Installed Device’s operating system. For this, no Collected Data is transferred to SONY.)

    (1) Notifying updates of the Application

    Each time you start the Application on your Installed Device, the Application sends a "re-quest" to SONY's server to check whether any updates for the Application are available and to notify you of the update information in case any update should be available. For this, we only use your application version.

    Please note that the legal basis for SONY processing your application version data for pushing updates to your Application or Related Device is the performance of the EULA we have with you.

    (2) Notifying updates regarding products registered in the Application

    The Application notifies you of firmware updates for the products you have registered in the Application. For this, we use the followings:

    • Device ID
    • Target Model information to receive update notifications (model name, purchase date)
    • Setting information regarding receiving update notifications

    Please note that the legal basis for SONY processing your Device ID, Target Model information, setting information is the performance of the EULA.

    (3) Improving/developing SONY’s products and services

    FOR EU RESIDENTS:
    SONY uses all of the Collected Data listed in Section 2 above to improve and develop SONY’s current and future products and services where you select "Agree and continue". Product improvement and/or development includes those relating to either an improvement of the technical functions of the Related Device (Information about the device which is connected to the Installed Device and which is detected by or registered to the Application) 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 logfiles of the app usage,
    - complementing our app with new useful functions if we determine malfunctions or other technical issues (e.g. new function to fix connectivity issues); or
    - change of default or other settings respectively accentuating specific settings/functions respectively ceasing certain functions, in any case to add value to your user experience.

    Please note that your consent forms the legal basis for SONY processing the Collected Data for improving/developing SONY’s products and services under EU-law is (Article 6 (1) (a) General Data Protection Regulation).

    SONY may collect information through following third-party module(s) embedded in the Support by Sony application and use such information as follows:

    *Information collected hereunder may be also sent automatically to each module provider.

    • SONY may collect "App usage history information" and "Endpoint ARN" through [AWS Mobile SDK (Amazon Web Services, Inc.)] for the purpose outlined in (1)(2)(3).
    • SONY may collect "device ID" and "Notification Token" through [Google API (Google, Inc.)] for the purpose outlined in (1)(2).

    You can withdraw your consent above at any time by selecting "Settings" > "Agreement to use of personal information to improve products and services" in the Application.

    FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:
    SONY uses all of the Collected Data listed in Section 2 above to improve and develop SONY’s current and future products and services. Product improvement and/or development includes those relating to either an improvement of the technical functions of the Related Device (Information about the device which is connected to the Installed Device and which is detected by or registered to the Application) 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 logfiles of the app usage,
    - complementing our app with new useful functions if we determine malfunctions or other technical issues (e.g. new function to fix connectivity issues); or
    - change of default or other settings respectively accentuating specific settings/functions respectively ceasing certain functions, in any case to add value to your user experience.

    SONY may collect information through following third-party module(s) embedded in the Support by Sony application and use such information as follows:

    *Information collected hereunder may be also sent automatically to each module provider.

    • SONY may collect "App usage history information" and "Endpoint ARN" through [AWS Mobile SDK (Amazon Web Services, Inc.)] for the purpose outlined in (1)(2)(3).
    • SONY may collect "device ID" and "Notification Token" through [Google API (Google, Inc.)] for the purpose outlined in (1)(2).

    4. Who else has access to your information?

    Your information that is communicated to and stored by SONY may be made available to other Sony Corporation's group companies and to third parties, as follows:

    SONY Affiliates
    The Collected Data may be shared with and used by other SONY Affiliates only on an aggregated/anonymized level for the purposes of product improvement/development as outlined in Section 3(3) above. SONY Affiliates" shall mean Sony Corporation, which is the ultimate parent company of SONY and any legal entities controlled by Sony Corporation. SONY and SONY Affiliates shall be collectively referred to as "SONY Group". 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.

    Service Providers
    SONY and SONY Affiliates may use 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.

    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. 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 after such transaction.

    Government Authorities/ Law Enforcement Officials
    Personal 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 personal data to auditors or similar external consultants like lawyers or tax advisors, to exercise our legal rights (e.g. enforcing compliance with the terms of use) and to help us fulfill our legal obligations.

    5. Data Retention, Managing Your Information

    We will retain the Collected Data for as long as you use the applications and for a period of 24 months after your latest use of the Application. Please note that some or all of the Collected Data may be required in order for the Application to function properly, and we may be required to retain certain information by law. 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 your information internationally and Consent to processing

    FOR EU RESIDENTS:
    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 or an appropriate Privacy Shield certification. Where the Collected Data is transferred to Japan, the adequate level of data protection is confirmed by the European Commission's adequacy decision.

    FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:
    The Collected Data will be processed, stored and transferred for the purposes outlined in Section 3 to countries/regions outside your country/region of residence, including in particular Japan and the United States. By using this 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 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 your information. Although we strive to protect your information, we cannot guarantee or warrant the absolute security of any information transmitted to us through the application or that we store on our systems or that is stored on our third-party contractors' systems.

    8. Our Policy Regarding Children

    SONY 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. 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. If you are a parent or guardian and are concerned that your child has provided us with personal information without your consent, you should contact us as indicated below (Section 11).

    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 the right to request that SONY or the SONY Affiliate amends, erases, destroy, deletes, blocks/restricts the further processing and/or use of such Collected Data 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). 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 us as described in 11. Contact Information below.

    10. Changes

    SONY will notify you of any changes to SONY’s Privacy Policy by prominently posting notice of the amendment on the Application. You can consult the latest Privacy Policy at any time by selecting "Settings" > "Privacy Policy" in the Application.

    11. 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.

    FOR RESIDENTS IN THE EU:
    If you are in the EU: Sony Marketing Inc., 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.

    FOR RESIDENTS IN THE UK:
    If you are in the United Kingdom: Sony Marketing Inc., 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.

    FOR RESIDENTS IN KOREA:
    We 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 Group Companies at:

    The US [and Canada]: privacy@am.sony.com
    Americas other than the US: http://www.sony-latin.com/locale-selector
    Africa and Middle East: https://www.sony-mea.com/en/locale-selector
    Asia & Oceania: http://www.sony-asia.com/countryselector.html

    If you are not satisfied with how we have handled your questions or concerns, or have any complaints about how we process Collected Data, you have the right to complain to the local data protection supervisory authority in the place where you live or work or in the place where you believe a breach may have occurred.

    12. Privacy Rights (including EEA and California/Other U.S. State Privacy Rights)

    In some countries, including countries in the EEA, you have certain rights with respect to the personal information Sony holds about you. These may include rights to: request a copy of the personal information that we hold about you, and/or you may request that we correct, amend, delete the Information if it is inaccurate. In some countries, including countries in the EEA, you may also ask us to provide some types of the Information to you in a structured, machine readable format and ask us to share (port) such data with another controller. 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 us as described in Section 11 above.

    SONY Group’s Privacy Rights for EU Residents:
    With regard to your Collected Data that we process if you are located in the EU/EEA, you may have the following rights pursuant to Art. 15-18 and Art. 19-21 GDPR:

    • You have the right to access (including a copy of) your Collected Data (Art. 15 GDPR); to correct, delete or restrict (stop any active) processing of your Collected Data (Art. 16- 18 GDPR); and to obtain the Collected Data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this Collected Data to another controller (Art. 20 GDPR).
    • In addition, you can object to the processing of your Collected Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing - Art. 21 GDPR).
    • Where we have asked for your consent, you may withdraw consent at any time (Art. 7 para 3 GDPR). If you ask to withdraw your consent to SONY processing your data, this will not affect any processing which has already taken place at that time.

    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 us.

    You also have the right to complain to a supervisory authority for data protection 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.

    Notice to California Residents:
    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

    13. Additional Notice

    FOR RESIDENTS IN THE PHILIPPINES:
    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 re-lating to the processing of the Collected Data by an acquiring entity in the event a business transfer as described in paragraph 4 of this Privacy Policy takes place.

    Last Updated: 25-06-2020