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Sony Mobile Communications AB (“Sony Mobile”) is the Sony Mobile group company acting as the data controller in connection with any personal information collected or received by Sony Mobile arising from your use of any Sony Mobile products, services, applications, websites (including any e-commerce stores) and contact centres made available to you.
This Policy explains the types of information that we may collect and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries or concerns about this information.
Please note that other companies in the Sony group are responsible for their respective data processing activities in connection with other Sony products and services. 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. Information that we collect
2. How Sony Mobile uses the information that you provide or which it collects
3. Sharing information about you
4. Linked Sony accounts (“One Sign In”)
5. International transfers of your information
6. Marketing communications
7. Security of your personal information
9. Access to your information and your rights
10. Links to third party sites
11. Children’s privacy
12. California Residents Privacy Rights Notice
13. Notice for Australia Residents
14. Notice for New Zealand Residents
15. Notice for Malaysia Residents
16. Notice for Singapore Residents
17. Contact us
1. Information that we collectclose
What personal information does Sony Mobile collect and where does this information come from?
Sony Mobile may collect information about you in several different ways. Please take care when submitting information to us, in particular when completing free text fields or uploading content, documents and other materials. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.
- Information that you provide us
Whenever you interact with Sony Mobile, you may be asked to provide us with information relating to you. For example:
- Some of our applications or services require you to create an account. When creating your account(s), we may ask you to provide a range of information, 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 marketing preferences and your current mobile network operator
- When you purchase, register, send for repair or return one of our products via any one of our authorised channels , we may ask you to provide information such as your contact details, applicable device ID (s) relating to your particular product(s), delivery date and place of purchase and payment information
- When you contact our customer service centres for assistance (by any means of communication including written communications or via our website(s), support forums, telephone, email, sms, or our social media channels), we may record all customer service calls and keep information about the particular communication, including your name, the product(s) you bought, the reason why you contacted us, applicable device ID(s) relating to your particular product(s), and the advice we gave you so we can track the resolution of any customer service issues and for customer service training purposes
- When you join and/or participate in one of our loyalty programs, we may collect information relating to your use of the loyalty program and the rewards that you claim
- When you visit us at a public event, such as trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for information, such as your business card, name, contact details, interests and marketing preferences
- 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
- Information we collect from other sources
We may also collect information from publically available sources and third parties, including:
- When you seek to make a purchase from us, we may carry out credit and financial checks to ensure payment is not made fraudulently and that you have a suitable credit rating
- If you purchase products or services from a Sony Centre, mobile network operator or other retailer, we may receive certain information about your purchase from that retailer
- We may also receive information 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 the “Linked Sony accounts” section 4 below)
- Information we collect in relation to social networks
If you use any of our social network applications, pages or plug-ins or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts.
- 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, however, they might include your social network ID, name, profile picture, gender and locale. We may also receive additional information from your profile if you give us permission to access it
- If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you
- If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings
- Information we collect when you use websites, products, services and applications from Sony Mobile
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 information about your use of them, including:
- Details of your usage patterns, the content (including any advertisements) that you view and interact with including information on the services and applications you are using in device to personalise services to your specific needs. For example, when you use our websites, we may collect information about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket
- Service, product or server logs, which hold technical information 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.
- Device Information such as your device ID(s), including information about where your device is physically located. For example, when you are using a geo-location service or application and you have provided consent to your location being shared
- With your explicit consent, information related to your physical behaviour health, and biometric data such as voice authentication data, fingerprint or facial characteristics or features
- Interests and preferences that you specify during setup of the Internet enabled product or service
- Details of your linked Sony accounts and when and how you used them (for more information about linked Sony accounts, see the “Linked Sony accounts” section 4 below)
2. How Sony Mobile uses the information that you provide or which it collectsclose
How does Sony Mobile use your personal information?
Sony Mobile may use the information you provide or which it collects for a wide range of purposes, including:
Sony Mobile may use information it collects for the following purposes:
- Provide you with a product or service you have requested (including any back up and restore service), delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and fulfil its obligations under any other agreement it may have with you)
- Fraud prevention and investigation purposes, for example, using device information such as device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, checking that a payment is not made fraudulently
- Create and manage customer database(s) of its 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 ongoing customer relationship management activities, we may consolidate several databases into one or otherwise link separate databases to more effectively manage your accounts.
- Provide you with software updates, (your device will send its device ID to us). These updates may contain critical security and functionality patches that make your phone more secure (protecting all the personal data on your phone) and improve its performance.
- For staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other customer support centres
- Ask for your opinions on Sony Mobile products and services and conduct product surveys
- Facilitate and process your searches and requests for information when you contact us about Sony Mobile and its products and services
- Conduct prize draws, contests and other promotional offers
- Consider employing you if contact us via one of Sony Mobile ’s job application websites
- Checkout assistance service
When you use our applications and services including any online e-commerce stores, such as Xperia store, details of any products that you seek to purchase and your email address may be collected as you fill in the checkout form. If you do not complete your purchase, we and/or our authorised fulfilment partner(s) may contact you using these details to offer our assistance (in case, for instance, you were experiencing technical difficulties which prevented you from completing any transaction).
This is an optional service. You can choose not to receive our checkout assistance emails at any time by following the link at the bottom of each assistance email.
- Marketing communications
Sony Mobile and/or other Sony group companies may use your information to provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging and/or text message (SMS), if you have provided your prior consent or we are otherwise permitted to do so under applicable law. See the Marketing communications section 6 below for more details.
- Personalised content, recommendations and advertisements
Sony Mobile may use the information it collects and/or any information about you which is shared with us (eg from other Sony group companies whose products, applications and services you also use) to personalise its stores, services, content, recommendations and adverts. You may notice this personalisation when you use Sony Mobile products and services, when we send you marketing communications and when you visit our 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).
- Statistics and Research
Sony Mobile may use your information to create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programs, which we may share with third parties and/or make available to the public.
- Product/Services Improvement
Sony Mobile may use your information to improve and enhance existing Sony Mobile products, services and applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ shopping preferences in general.
- Publish your reviews, comments and content
Where you have uploaded product reviews, comments or content to our websites or services and made them publically visible, Sony Mobile may link to, publish or publicise these materials elsewhere including in our own advertisements.
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 and to select or tailor our marketing communications to reflect your forum activity. We do not use the actual content of your forum posts or threads for purposes of sending marketing communications.
- Combining the information we collect
We may link or combine the information that we collect from the different sources outlined above in the “Information that we collect” section 1 above (including information received from other Sony group companies about your use of other Sony group products and services). Information 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 the “Linked Sony accounts” section below). Alternatively, we may decide to combine two or more databases into a single database of customer information.
We may do this for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide a more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts.
3. Sharing information about youclose
How is information about you shared within Sony and with 3rd parties?
- Sharing of information by Sony Mobile
In general, Sony Mobile does not disclose information about you to third parties without your consent. However, there are exceptions:
- Other Sony group companies
We may disclose information about you 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 any customer preference information as provided by you from time to time) to other Sony group companies where
(i) 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 data in accordance with our instructions and shall be subject to appropriate confidentiality and security obligations; or
- Sony Centres
If you choose to purchase products or services from a Sony Centre (whether in store, through our website or over the telephone), your purchase information may be shared by Sony Mobile with that Sony Centre. Your purchase information may be combined with other data that that Sony Centre holds about you as a customer, such as details of other purchases you have made.
- Our service providers
We may use other Sony group companies and/or third party service providers to provide certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include billing and fulfilment partners, data analytics providers who process information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide customer services.
When acting as our authorised data processors, our service providers (including Sony group companies) are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
- Third Party Advertising Partners
- Third party newsletters
If you request or agree to receive information or newsletters from one of our business partners, we may provide that third party with your details so that they can contact you and/or respond to your request.
- Legal and business purposes
We may use and/or disclose to third parties information about you:
(i) To government bodies and law enforcement agencies to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information request s from such bodies
(ii) To third parties (including professional advisors) to enforce or defend the legal rights of any Sony group company or the terms and conditions of any Sony product or service
(iii) To a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation
- 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 partners, advertisers, industry bodies, the media and/or the general public).
- Other Sony group companies
- Sharing of information provided by you
A number of our applications and services allow you to upload and share messages, photos, video and other content and links with others and/or create a publically 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 allow you to share a link which if clicked on may allow the recipient to access your uploaded content
Please be aware that any content and links that you share via Sony Mobile’s applications and services might, for instance, be forwarded by your recipients to others. You should always exercise discretion when using such applications and services.
We ask our users to take responsibility for protecting their own privacy online and to also respect the privacy of others. Participants of any communities, forums and message boards are prohibited from disclosing their own personally identifying information other than their own online IDs. Disclosure of phone numbers, addresses, age or other personally identifying information that may violate someone else’s privacy is prohibited. Encouraging or asking users to disclose publicly their personally identifying information is also prohibited.
4. Linked Sony accounts (“One Sign In”)close
What are linked Sony accounts and how are they used?
Your accounts for different Sony applications and services can be linked together so you can use the same sign in details (email address and password) to access them all (“One Sign In”). Other basic account details are also synchronised across your linked accounts, so you can more easily manage your accounts.
- How are they used by Sony group companies?
However, Sony group companies may generally use information relating to your linked Sony accounts for the following purposes:
- 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); or
- make changes to your basic account details (as these details are synchronised, changes will automatically be made across all of your linked accounts).
- Customer Support
When you have linked accounts for Sony services, any Sony call, email or other support centre for those services may access your basic account details to handle your queries. As above, changes you make via customer support will automatically be made across all of your linked accounts.
- Notification of news, competitions and offers from Sony
You may be offered the opportunity to sign up to receive information about Sony group news, competitions and offers. If you do, companies in the Sony group may send you their news, competitions and offers and may use your linked Sony accounts to make this information more relevant to you.
- Customer analysis
Information 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)
In the event 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 informationclose
How does Sony Mobile transfer information about you to other countries?
Sony Mobile is part of the Sony group, which is a global organisation. For the purposes explained in this Policy, your information (including your linked account details – for more information about linked Sony accounts, see the “Linked Sony accounts” section 4) 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 where you are located. Each of those Sony group companies (and their authorised data processors) will however comply with Sony Mobile’s internal policy relating to processing of personal data which complies with the key data protection principles of fair handling of personal data and ensuring adequate level of protection of personal data.
6. Marketing communicationsclose
How does Sony Mobile use your personal information to send you marketing communications and how can you change your marketing preferences?
When you provide us with contact details, such as when you purchase a product, contact our customer support call centres or create an account for one of our services, you may be given the opportunity to opt-in to (or in certain cases where applicable law allows, opt-out of) receiving various newsletters and other communications from Sony Mobile and/or other Sony group companies. These communications may include, for instance, details about the latest Sony products and services, including upgrades and special offers in which you may be interested.
You can change your marketing communication preferences at any time:
- If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the email. But note that:
- If you use more than one e-mail address to shop or contact Sony Mobile, you will need to unsubscribe separately for each email address
- This method will only unsubscribe you for emails. You will need to separately unsubscribe for other types of marketing communications you receive.
- If you have registered with any applications and services provided by Sony Mobile and have your own account, you may log-in and amend your marketing communication preferences in the account settings page or area
- You can contact us using the details in the “Contact us” section below in order to change your marketing communication preferences
Please note that we may occasionally send you important information (including via email) about Sony Mobile products and services that you are using or have used including 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 or after sales repair services.
These important product and/or service communications are not affected by your marketing communication preferences.
7. Security of your personal informationclose
How does Sony Mobile protect your personal information and what can you do to protect yourself?
- What we do to protect your information
While Sony Mobile can’t guarantee that unauthorised access will never occur, rest assured that Sony Mobile takes great care in maintaining the security of your personal data to prevent unauthorised access to it through the use of appropriate technology and internal procedures.
We take a number of steps to protect your information from unauthorised access, use or alteration and unlawful destruction, including where appropriate:
- Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us)
- Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access)
- Putting in place physical, electronic, and procedural safeguards in line with industry standards
- What you should do to protect your information
As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
- Do not use trivial passwords (such as single dictionary words)
- Do not use the same password for multiple accounts
- Do use very long passwords (at least 10 characters, but preferably much longer)
- Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
- Do keep passwords securely (never written down, or shared with anyone) and changed periodically
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 customisation settings you have previously specified, and our ability to personalise your online experience would be limited. Please refer to your browser instructions to learn more about these functions.
9. Access to your information and your rightsclose
How can you access your personal information and what are your rights?
If you would like a copy of the personal information that we store about you in our customer databases, please contact us using the details given in the “Contact us” section below. You may be asked to provide some proof of identification so that we can verify that it is you making the request. We reserve the right, subject to applicable law, to charge a fee (subject to any cap on fees as required by applicable law) for inspection of your personal data held by us.
This is in addition to your legal rights, including the right to access a copy of your personal information, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact us” section below.
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 information 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 “How Sony Mobile uses the information that it collects”, 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.
10. Links to third party sitesclose
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 should view the privacy and cookie policies displayed on those third party websites to find out how your personal information may be used.
11. Children’s privacyclose
Sony Mobile considers a child to by anyone under the age of 16. We do not knowingly seek or collect personal information from or about children in contravention of any applicable laws and regulations.
If Sony Mobile becomes aware that personal information 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 information from its files as soon as possible
- Ensure, where deletion is not possible, that this personal information 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 information relating to their child should contact us using the details provided in the “Contact us” section.
12. California Residents Privacy Rights Noticeclose
California residents have the right to receive: a) information identifying any third party company(ies) to whom Sony Mobile may have disclosed, within the past year, personal information pertaining to you related to direct marketing purposes; and b) a description of the categories of personal information disclosed. Please email your request to Contact us
“Do Not Track” Signals. Your browser settings may allow you to automatically transmit a so called “Do Not Track” signal to websites and online services you visit. Sony Mobile currently does not alter its practices when it receives a “Do Not Track” signal. More information is available at http://www.allaboutdnt.com. Also note that third parties may collect personal information about your online activities over time and across different websites when you visit our websites or other online websites and services.
13. Notice for Australia Residentsclose
In relation to Section 5 “International transfers of your information” above, we will disclose your personal information to parties in a number of countries, including Singapore, New Zealand, the United States of America, Japan, the United Kingdom, Sweden and Belgium. From time to time we will need to disclose your personal information to parties in other countries not on this list. This will be on an ad hoc or case by case basis and for the purposes for which we collected your personal information.
Complaints: If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia). We will deal with complaints as follows:
- Step 1: let us know
If you would like to make a complaint, you should let us know by contacting our PIM Officer at firstname.lastname@example.org or the details set out in section 17 “Contact us” below.
Step 2: investigation of complaint
Your complaint will be investigated by our PIM Officer. A response to your complaint will be provided in writing within a reasonable period.
Step 3: contact OAIC
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
- Office of the Australian Information Commissioner (OAIC)
- Complaints must be made in writing
- Tel: 1300 363 992
- Address: Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
- Web: www.oaic.gov.au
14. Notice for New Zealand Residentsclose
Nothing herein shall limit the rights of customers under the Privacy Act 1993. All instructions regarding your data and queries from you will be followed up and answered by us as soon as possible.
15. Notice for Malaysia Residentsclose
A data subject has the following rights under the Act:-
- i. Request for access to personal data held on the individual, the purpose for which the personal data is being used and those to whom it has, or can be disclosed;
- ii. Prevent data processing that is likely to cause distress or damage;
- iii. Take reasonable action to stop the use of, rectify, erase, and/or dispose of inaccurate personal data; and
- iv. Withdraw their consent given to Sony Mobile.
16. Notice for Singapore Residentsclose
- Write in: Data Protection Officer
Sony Mobile Communications International AB, Singapore Branch
2 International Business Park, #01-10 Tower One, The Strategy
- Write in: Data Protection Officer
Sony Mobile will generally be able to respond to such queries and/or requests within 30 days.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Sony Mobile may not be able to continue to provide its products and/or services to you.