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 create the Account
In order to use certain services, you will need to create and sign into the Account. If you choose to create an Account, Sony will assign a Global Unique Identifier (“GUID”) and collect the following personal data you input when creating the account (which, along with GUID is referred to collectively as “Collected Data”):
·Date of birth;
·Address (Country/Region and/or City);
Once you have successfully signed into your Account, your device will receive a digital ‘access token’ from such Account.
Please note that Sony receives information about your usage of the website of the Account (access status, traffic, routing, etc.).
If you use “Imaging Edge” mobile applications, PC software and/or web services (collectively, “Imaging Edge”), Collected Data will be linked to and analyzed in conjunction with your information collected through the Imaging Edge by using your GUID only for the purposes set forth below. Also, if you use the Imaging Edge with PlayMemories Home on the same PC, Collected Data will be linked to and analyzed in conjunction with your information collected through PlayMemories Home by using your GUID solely for the purposes set forth below.
2. How Sony uses Collected Data
Sony processes Collected Data in order to perform its contract with you to:
·provide you with certain function of the Imaging Edge (if you use the Imaging Edge);
·maintain and control your Account; and
·respond to your inquiry about the Account.
Sony also processes Collected Data in order to pursue its legitimate interests in:
·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, develop new ones, and 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.
·Protecting Sony Group Companies and the Account holders
Sony may collect and/or analyze Collected Data in order to identify potential security threats and to protect Sony, Sony Group Companies and the Account holders.
Sony will share Collected Data with third parties for their direct marketing purposes with your consent.
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
Collected Data will be shared with Sony Corporation, Sony Network Communications Inc., and Sony Interactive Entertainment LLC (whose servers are located in the US).
We will also share: i) Collected Data with Sony Group Companies, which locally sell and provide our products and services; and/or ii) Collected Data which has been de-identified with Sony Group Companies, our network advertisers 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 visiting TRUSTe's website here. 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.
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 6 months after you delete the Account (or for so long as is allowed by local law). Please note that we may be required to retain certain information by law.
5. International Transfer of Collected Data
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 11 below.
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 that we store on our systems or that is stored on our third party contractors’ systems.
7. Children’s privacy
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 11 below.
8. Privacy Rights (including EEA and 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 11 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, please contact us as described in Section 11 below.
9. Cookies and other tracking technologies
11. Contact Information
FOR RESIDENTS IN THE EU:
You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at https://sony-europe.com.
FOR RESIDENTS IN THE UK:
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.