Privacy Policy for “Imaging Edge” Applications/Software/Web Services

This Privacy Policy sets out how Sony Imaging Products & Solutions Inc., (of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan) (“Sony”, “we”, “our” or “us”) collects, uses and/or stores the Collected Data (defined as below) regarding your “Imaging Edge” mobile applications, PC software and/or web services (collectively, “Imaging Edge”). It also describes your data protection rights, including a right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 below.

For the purposes of Regulation 2016/679 (the "GDPR"), Sony is the "data controller" of your personal data.

“Sony Group Companies” shall mean Sony Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony 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).

1. What personal data do we collect when you use the Imaging Edge

Sony collects information or data as described below which may include personal information (collectively, the “Collected Data”) related to your use of Imaging Edge.

Information collected through the Imaging Edge

When you use each of the following Imaging Edge, Sony will collect the following information respectively:

Please note that Sony also automatically receives device usage information about how you are using and interacting with the Imaging Edge, for example: information about which of the Imaging Edge functions you choose to use, picture transfer times and movie recording time.

If you install and use more than one Imaging Edge on the same device, Collected Data collected through either one will be linked to and analyzed in conjunction with Collected Data collected through the other by using your GUID or UUID only for the purposes set forth below. Also, if you use the Imaging Edge with PlayMemories Home on the same PC, Collected Data collected through the Imaging Edge will be linked to and analyzed in conjunction with the data collected through PlayMemories Home by using your GUID or UUID solely for the purposes set forth below.

2. Purposes and legal basis for processing Collected Data

Contract

Sony processes Collected Data in order to perform its contract with you to provide the Imaging Edge.

Legitimate Interest

Sony also processes Collected Data in order to pursue its legitimate interests in:

1.       Improving, developing and marketing products and services

Sony will collect and/or analyze Collected Data in order to improve Sony Group Companies’ products and services and to develop new ones, and to market and predict the demand for those products and services so that we can provide improved users’ experiences for current and/or future products and services.

2.       Protecting Sony Group Companies and the Imaging Edge users

Sony may collect and/or analyze Collected Data in order to identify potential security threats and to protect Sony, Sony Group Companies and the Imaging Edge users.

3.       Providing certain information and service related to your Sony digital camera product

If you use Sony digital camera product with the Imaging Edge, Sony will use Collected Data in order to provide you with information and recommendation regarding your Sony digital camera product and support service including repair of your digital camera product and response to your inquiry.

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

As required by law

We also process Collected Data where required to do so by applicable law, for example in response to requests by government or law enforcement authorities conducting an investigation.

3. Who else has access to Collected Data?

Collected Data that is communicated to and stored by Sony will be made available to other Sony Group Companies and to third party as follows:

Sony Group Companies and third party contractors

We will share anonymous analysis data of Collected Data with Sony Group Companies, which locally sell and provide our products and services, solely for the purposes set forth above.

In addition, we will share Collected Data with Amazon Web Services who provides data back-up service to us, and which is located in the US. This contractor is engaged for the purposes of pursuing the activities outlined in this Privacy Policy on Sony’s behalf, acting as processors of Sony.

Firebase Crashlytics

The Imaging Edge uses Firebase Crashlytics, a service provided by Google Inc. (“Google”). Firebase Crashlytics will track, prioritize and fix stability issues that erode quality of the Imaging Edge you use. To better understand how Google uses the information it receives, visit: https://policies.google.com/privacy.

Business transfer

In the event that we sell or transfer a portion or all of our business, Collected Data may be transferred by us to the purchasing or acquiring entity as part of the transaction. In the event we sell or transfer Collected Data to a purchasing or acquiring entity you will be duly informed.

Compliance and enforcement

We will retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.

4. Data Retention, Managing Collected Data

We will continue to retain Collected Data for as long as we continue to make the Imaging Edge available to customers, and for a further 6 months following discontinuation. Please note that we may be required to retain certain information by law.

5. International Transfer of Collected Data

Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan and the US. Collected Data will be processed by staff operating outside the EEA and/or your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries.

Sony takes appropriate measures to ensure that all transfers of Collected Data from the EEA to countries outside the EEA meet the requirements of applicable EU data protection legislation. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. If you have any questions or concerns about Sony's data transfer arrangements please contact us using the details at Section 10 below.

6. Security

Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive to protect Collected Data, we cannot guarantee or warrant the security of any information transmitted to us through your Imaging Edge or that we store on our systems or that is stored on our third party contractors’ systems.

7. 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. 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 in Section 10 below.

8. Privacy Rights (including California 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 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 10 below.

As of January 1, 2005, California Civil Code Section 1798.83 (the “Code”) permits users who are California residents to request certain information regarding the disclosure of personal information to third parties which is used for their direct marketing purposes. To make such a request, to which Sony shall respond to the extent required by the Code, contact us as described in Section 10 below.

9. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (whenever necessary under the applicable law) of any changes to this Privacy Policy through the Imaging Edge.

10. Contact Information

FOR RESIDENTS IN THE EU:

If you have any questions or concerns about this Privacy Policy or if you wish to exercise any legal right you have in respect of Collected Data, please contact Sony Europe Limited, who is Sony’s representative in the EU, at:

privacyoffice.seu@sony.com

You can also get in touch by writing to Sony Europe Limited, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at http://sony-europe.com.

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: privacy@am.sony.com

Americas other than the US: http://www.sony-latin.com/locale-selector

Africa, Middle East and 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.

Last Updated: February 1, 2019