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Sony Mobile Privacy Policy

Please read this Important Privacy Notice

This Privacy Policy was last updated in January 2020, prior policies are archived here

Overview

Your privacy and trust are important to us. This Privacy Policy explains the types of personal information and data (hereinafter “personal data”) that we may collect and hold, how that personal data is used and with whom the personal data is shared. You will find contact information at the end of this Privacy Policy if you have any queries or concerns.
Sony Mobile Communications Inc. (hereinafter “Sony Mobile”, “we”, “us” or “our”) is the Sony group company responsible for any personal data collected or received by Sony Mobile arising from your use of any Sony Mobile products, services, applications and websites made available to you. Sony Mobile is also responsible for ensuring that the handling of personal data complies with this Privacy Policy.
Our products and services evolve constantly, and we will adjust this Privacy Policy to accurately describe what personal data we collect, how we use it and with whom we are sharing the personal data, as well as if required to comply with changes in applicable laws. If we make changes to this policy, we will change the last-updated date (see top) and update this page. If we make material changes, we will notify you as required by law. Please check from time to time what changes we have made.
Please note that other companies in the Sony group are responsible for their respective personal data processing activities in connection with the other Sony products and services that they may offer. These Sony group companies may have their own privacy policies, which are generally available from the relevant websites for those products and services.
Click on the relevant section heading to expand that section:

1. Personal data that we collect
2. How Sony Mobile uses your personal data about you
3. Sharing your personal data
4. Linked Sony accounts (“One Sign In”)
5. International transfers of your personal data
6. Security of your personal data
7. Cookies & Tracking
8. Retention of your personal data
9. Children’s privacy
10. CALIFORNIA PRIVACY NOTICE
11. Specific Notices
12. Contact us

1. Personal data that we collect

Sony Mobile may collect personal data about you in several different ways. We may collect information directly from you, automatically from your device, or from third parties. The ways in which we collect information are further explained below. Please take care when submitting personal data to us.
A. Personal data that you provide us
Whenever you interact with Sony Mobile, you may be asked to provide us with personal data relating to you. For example:
• Some of our applications or services may require you to create an account. When creating your account(s), we may ask you to provide a range of personal data, such as your name, date of birth, location, contact details, applicable device ID(s) relating to the devices you are using to access and receive particular applications and services, interests and account and your current mobile network operator
• When you use our applications and services or other platforms, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive. Further, use of applications with voice recognition may require us to access certain personal data on your device and also record your voice
• When you specify interests and preferences during setup of a Sony Mobile device or service
B. Personal data we collect when you use our websites, products, services and applications
In order to improve and provide a better user experience, some of our websites, internet-enabled products and applications and services provide Sony Mobile with personal data about your use of them, including:
• Details of your usage patterns, content that you view and interact with including personal data on the services and applications you are using on-device to personalise services to your specific needs
• Device information and service, product or server logs which hold technical personal data about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin. Your device ID is also collected when you download a software update
• Location information including personal data about where your device is physically located. For example, when you are using a geo-location service or application and you have given consent to your location being shared
• With your explicit consent, personal data related to your physical behavior or health
• Voice recognition and utterance data when using a voice command application. Such data may be sent to our technology partners
• Details of your linked Sony accounts and when and how you used them (for more information about linked Sony accounts, see section 4 below)
C. Personal data we collect in relation to social networks
If you use any of our social network features, pages or plug-ins, or you use our products or services that allow interaction with social networks, we may receive personal data relating to such use. For instance:
• If you log in to one of our websites, applications or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings. Typically; however, they might include your social network ID, name, profile picture, gender and locale. We may also receive additional personal data from your profile if you give us permission to access it
• If you ‘like’ or similar one of our pages on a social network site, we may receive personal data about your social network profile, depending on your social network account privacy settings
For more information and for details about how you can control access to your social network profile, you should view the privacy policy and other guidance available on your social network’s website.
D. Personal data we collect from other sources
We may also collect personal data from publicly available sources and third parties, including:
• If you purchase products or services from a regional Sony sales company or authorized retailer, we may receive certain information about your purchase from that retailer, such as your IMEI code, contact information and time of purchase
• We may also receive personal data about you from other Sony group companies that you interact with; in particular, when you link your accounts for certain Sony group services (for more information about linked Sony accounts, see section 4 below)

2. How Sony Mobile uses your personal data

How does Sony Mobile use your personal data?
Sony Mobile uses the personal data you provide or which we collect mainly for these purposes:
A. Service provision
We may use data we have collected, including personal data, to:
• provide you with a product or service you have requested, including any back-up and restore service
• process your registration with us or create an account
• provide you with required notices and software updates which may contain critical security and functionality patches that make your device more secure and protect the personal data on the device
• send important information (including via text message, push notifications, email) regarding essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty
B. Product and service development
We work constantly to develop and improve our products and services to better meet customer requirements, to ensure quality, and to strengthen network and information security. We may use personal data to:
• create and manage customer database(s) of our users, including basic account information (such as your name, date of birth, address, contact details), applicable device ID(s) (relating to the devices you are using to access and receive particular applications and services), related product or service usage information and customer preference information as provided by you from time to time. As part of our on-going customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accounts
• improve and enhance existing Sony Mobile products, services and applications and develop new offerings in general
C. Personalization
We may use personal data to personalize your customer experience. In particular, we may:
• show you personalized content, recommendations and advertisements. You may notice this personalization when you use Sony Mobile products and services and when you visit our own and third-party websites that show advertisements from us or our advertising partners. For example, you might see an advertisement for a product that you have recently viewed on one of our websites. Some of the personalization that you see on our websites or in our online advertisements makes use of cookies set by us or our third-party advertising partners. In other cases, our applications and services may have specific settings to control personalized content; you should consult the applicable terms and conditions of the relevant application or service for more information
• use product reviews, comments or content you have uploaded and made publicly visible in our websites or services to link to, publish or publicise elsewhere. Each time you create or reply to a post or thread on a website forum from Sony Mobile, in addition to providing this forum service, we may also record the forum name and the time and date of your post or thread with your account details. We do this to better understand the ‘typical users’ of our forums. We do not use the actual content of your forum posts or threads for purposes of sending marketing communications
If you want to know more about tracking and cookies and how to opt-out, see section 7 below for more details.
D. Fraud prevention and investigation
Sony Mobile may use personal data to prevent fraud and to investigate violations or our policies. We may use personal data to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies. We may use your personal data to enforce or defend the legal rights of any Sony group company or the terms and conditions of any Sony product or service.
E. Other purposes
We may use your personal data for other purposes:
• to link or combine the personal data that we collect from the different sources outlined above (including personal data received from other Sony group companies about your use of other Sony group products and services). Personal data may be linked via a unique identifier, such as a cookie or account number (particularly when you link Sony accounts – for more information about linked Sony accounts, see section 4 below)
• alternatively, we may decide to combine two or more databases into a single database of customer information. We may link or combine personal data for your and/or our convenience (for example, to allow you to more easily register for a new service) and to provide you with better, personalised services and content

3. Sharing your personal data

How is personal data about you shared within Sony and with third parties?
A. Sharing of personal data by Sony Mobile
In general, Sony Mobile does not disclose personal data about you to third parties without your explicit consent. However, there are exceptions:
• Other Sony group companies
We may disclose personal data about you including basic account information (such as your name, email address, address, contact details), applicable device ID(s) (relating to the devices you are using to access and receive particular applications and services), related product or service usage information and any customer preference information as provided by you from time to time) to other Sony group companies where:
o you have linked your Sony accounts, as further described in Section 4
o we have engaged such other Sony group companies to provide data processing services to us (and these other Sony group companies will only process your personal data in accordance with our instructions and shall be subject to appropriate confidentiality and security obligations)
o you use your Sony Mobile devices and/or applications or services to access, purchase or download content, services, applications or products that are published, developed, supported or offered by other Sony group companies. They may combine this personal data with other details they hold about you. Unless they provide you with their own privacy policy, they may use your personal details for the purposes explained in this Privacy Policy. Where you have multiple accounts with different Sony group companies, these Sony group companies may also share personal data with us in accordance with their own privacy policies
o Sony Mobile transfers a portion or any part of our business to another Sony group company
• Our service providers
We may use other Sony group companies and/or third-party service providers to provide certain data processing services for us. Examples of authorized data processors could include data analytics providers who process personal data on our behalf for the purposes outlined above. For example, we may use the services of third parties to send update or other important product messages (by SMS or email) or provide back-up services.
Please note that our third-party service providers (including Sony group companies) are required to only process data in accordance with our instructions, in line with this Privacy Policy, and are subject to appropriate confidentiality and security obligations.
• Legal and business purposes
We may use and/or disclose personal data to third parties:
o when we have a good faith belief that sharing the personal data with government bodies and law enforcement agencies is necessary to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies
o when we are defending or enforcing the legal rights of any Sony group company or the terms and conditions of any Sony product or service and sharing the personal data with third parties, including professional advisors, will be beneficial for our legal position
o in connection with a corporate event such as a merger, business acquisition or insolvency situation, when sharing the personal data with a prospective third-party purchaser or seller, and its and our professional advisors, is necessary
• Anonymous statistics
We prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party, such as our business partners or industry bodies.
B. Sharing of personal data provided by you
Some of our applications and services may allow you to upload and share messages, photos, video and other content and links with others and/or create a publicly accessible profile for your account. For example:
• The communities and forums area (where applicable) of our websites allows you to post comments (with your account name), which are visible to other users of that service
Other services may allow you to share a link which if clicked on may allow the recipient to access your uploaded content.

4. Linked Sony accounts (“One Sign In”)

What are linked Sony accounts and how are they used by Sony group companies?
You may be able to link your accounts for different Sony applications and services so you can use the same sign in details (email address and password) to access them all (“One Sign In”). Other basic account details may also be synchronised across your linked accounts so you can more easily manage your accounts. This Privacy Policy applies to our use of personal data relating to your linked account(s) and your use of our applications and services. Other applications and services from Sony are operated by different Sony group companies. The privacy policy of each service will tell you how your account details will be used in connection with that service, and which Sony group company is responsible (you can find the privacy policy for a service on its website). However, Sony group companies may generally use personal data relating to your linked Sony accounts for the following purposes:
A. Linking accounts/synchronised basic account details
We will share basic account details with another Sony group company when you:
• link your account for our services with your account for that Sony group company’s service(s)
• make changes to your basic account details (as these details are synchronised, changes will automatically be made across all of your linked accounts)
B. Customer analysis
Personal data relating to your linked accounts may be collated and analysed by the Sony group (in a manner that does not directly identify you) for product and service development, business promotion and research purposes and the results shared with other Sony group companies and third parties (even if you do not use any of their services)
After you have linked your accounts, the Sony group company operating each service you are accessing will continue to control your account for that service (and any data collected when you use that service) in accordance with its privacy policy. Linking your accounts does not change this. In the event that you wish to cancel or terminate some or all of your linked accounts, you will need to follow the account cancellation process for each individual service or account you wish to cancel. It will not be possible for you to cancel some or all of your linked accounts by contacting just one Sony group company. Each Sony group company can only process and action account cancellation requests for their own particular services.

5. International transfers of your personal data

How does Sony Mobile transfer personal data about you to other countries?
Sony Mobile is part of the Sony group, which is a global organization. For the purposes explained in this Privacy Policy, your personal data (including your linked account details) may be transferred to Sony group companies (including service providers operating on their behalf) and other third parties in countries which do not have the same level of data protection laws as those in the country, state or territory where you are located. Sony Mobile uses a variety of legal mechanisms to help ensure that your rights and protections will travel with your data. This is why each of those Sony group companies (and their authorised data processors) will comply with Sony Mobile’s internal policy relating to processing of personal data ensuring adequate level of protection of personal data.

6. Security of your personal data

How does Sony Mobile protect your personal data?
While Sony Mobile can’t guarantee that unauthorized access will never occur, rest assured that we take great care in maintaining the security of your personal data to prevent unauthorized access to it, through the use of appropriate technology and internal procedures. We take a number of steps to protect your personal data from unauthorized access, use or alteration and unlawful destruction and disclosure.
Does this Privacy Policy extend to third party websites visited when following links on our website(s)?
Some of our websites may contain links to other third-party websites that are not operated by Sony Mobile, including websites operated by other Sony group companies.
While Sony Mobile tries to link only to sites that share Sony Mobile’s high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those third-party websites. We strongly encourage you to view the privacy and cookie policies displayed on those third-party websites to find out how your personal data may be used.

7. Cookies & Tracking

What are cookies and how are they used?
Our websites use industry-wide technologies, such as “cookies”, to collect information about the use of our websites and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites. Cookies allow us to customise your experience to better match your interests and preferences, or to simply facilitate your signing in to use the services. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. However, if you block or erase cookies, we may not be able to restore any preferences or customization settings you have previously specified, and our ability to personalize your online experience would be limited. Please refer to your browser instructions to learn more about these functions. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, how browsers communicate “Do Not Track” signals is not uniform, and there is no standard application. Accordingly, Sony Mobile currently does not alter its practices when it receives a “Do Not Track” signal. More information is available at https://allaboutdnt.com/. Also note that third parties may collect personal data about your online activities over time and across different websites when you visit our websites or other online websites and services.

8. Retention of your personal data

How long will Sony Mobile keep your personal data?
We will only retain your personal data for as long as is reasonably necessary for the various purposes set out in section 2 above or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of personal data relating to our customers and/or any commercial transactions with them. Should any personal data held by us no longer be required by us for any of the purposes set out in section 2 above, we undertake to take reasonable steps to destroy or de-identify any personal data after a reasonable period of time has elapsed. If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact your local data protection authority.

9. Children’s privacy

What does Sony Mobile do regarding children’s personal data?
Sony Mobile considers a child to be anyone under the age of 16. We do not target users under the age of 16. If Sony Mobile becomes aware that personal data that has been submitted to it relates to a child in contravention of any applicable laws and regulations, Sony Mobile will use reasonable efforts to:
• Delete that personal data from its files as soon as possible
• Ensure, where deletion is not possible, that this personal data is not used further for any purpose, nor disclosed further to any third party
Any parent or guardian with queries regarding our processing of personal data relating to their child should contact us using the details provided in section 11 Contact Us below.

10. CALIFORNIA PRIVACY NOTICE

California Privacy Notice (Effective January 2020)

Our Practices Regarding Collection and Use of your CA Personal Information
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 may have additional rights with regard to how we use your information. We have included this California-specific information below.

A. CA Personal Information
Consistent with the “Personal data that we collect” section, we may collect the following categories of information about California residents (“CA Personal Information”) for the purposes described in the “How Sony Mobile uses your personal data” section of this Privacy Policy, specifically:
Personal Identifiers: such as name, mailing address, telephone number, email address and similar identifiers
Other Identifiers: such as Device IDs, IP address, or other unique identifiers;
Commercial Information: such as product or service types or applications purchased or obtained, or transaction information;
Internet or Other Electronic Network Activity: such as device data and connected device information, operating system, screen views, traffic to and from applications, other standard connectivity information;
Geolocation Data: such as data about your location, if you use location-based services;
Other Consumer Characteristics: such as demographics (e.g., gender, age, profession or job title, etc.), and inferences drawn from collected information

B. Sources of CA Personal Information
Consistent with the “Personal data that we collect” section above, we may collect CA Personal Information from the following sources:
Directly from you: such as when you voluntarily provide CA Personal Information to us when activating a product or registering an account, or when it is collected automatically from your Sony Mobile product;
Third-Party Business Partners: such as retail stores or mobile network operators;
Third-Party Applications: such as social networks or other blogs or chatrooms.


C. CA Personal Information Sold or Disclosed For Business Purposes

Sharing your CA Personal Information for Business Purposes: In the preceding twelve months, we may have shared the following categories of CA Personal Information for business purposes: Personal Identifiers, Other Identifiers, Commercial Information, Internet or Other Electronic Activity, Geolocation Data and Other Consumer Characteristics. This information may be shared with Sony group companies, third party business partners or legal authorities for the purpose of providing services to you, for product development, monitoring and quality assurance, managing and delivering communications, for legal compliance or to protect legitimate interests, in compliance with law.
Sale of CA Personal Information: We do not “sell” (as defined under the California Consumer Privacy Act) any categories of CA Personal Information.

D California Consumer Rights
Subject to certain exceptions, as a California resident, you may have the following rights with respect to your CA Personal Information:
Access: Request access to your CA Personal Information that we have collected, used or disclosed within the preceding 12 months;
Deletion: Request deletion of your CA Personal Information; and
CA Personal Information Disclosed for Business Purposes: Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months.
Please note, if you request deletion of your CA Personal Information, to the extent permitted by applicable law, we may be required to retain some of your CA Personal Information, and certain CA Personal Information is strictly necessary in order for us to fulfill the purposes described in this Privacy Policy. If you wish to exercise a right listed in this section, you may submit a request here: Data Requests.

E. Exercising Your Rights
If you are a California resident and wish to exercise any of these rights, please: (a) access the webform applicable to your request as described above, (b) contact us by sending an email to privacy@am.sony.com or write to us at the address in the “Contact Us” section below with the specific nature of your request, referencing “Your California Privacy Rights”; or (c) call the following toll-free number 1-833-681-9900. When submitting your request, you must include your first and last name, email address, and zip code or mailing address. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that you are limited by law in the number of requests you may submit per year.
We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, or in connection with any promotion or other offering, based solely upon you exercising your rights with respect to your CA Personal Information.
Authorized Agents: To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as required under the California Probate Code. We may require additional proof of authority or may need to contact you directly to validate the request.
Access Notice in Alternative Formats. California residents who need assistance accessing the notice in an alternative format can contact us at privacy@am.sony.com.

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, and a reference to “Your California Privacy Rights.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.

11. Specific Notices

Other State Rights / 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. We do 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 we 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 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.

12. Contact us

How can you get in contact with Sony if you have questions?
If you have any concerns about our practices regarding your data, please contact us:
Write to Sony Electronics Inc., Attn: Privacy Officer, 115 W. Century Road, Suite 250, Paramus, NJ 07652
Email privacy@am.sony.com
Call toll-free at 1-833-681-9900