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Sony Mobile Communications AB (hereinafter “Sony Mobile”, “we”, “us” or “our”) is the Sony Mobile group company acting as the data controller in connection with any personal data 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. Sony Mobile is responsible for ensuring that the processing of personal data complies with this Policy.
Please note that other companies in the Sony group are responsible for their respective personal 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. Personal data that we collect
2. How Sony Mobile uses your personal data about you
3. Sharing personal data about you
4. Linked Sony accounts (“One Sign In”)
5. International transfers of your personal data
6. Marketing communications
7. Security of your personal data
8. Cookies & Tracking
9. Access to your personal data and your rights
10. Links to third party sites
11. Children’s privacy
12. Local and Country-Specific Notices
13. Contact us
What personal data does Sony Mobile collect and where does this personal data come from?
Sony Mobile may collect personal data about you in several different ways which are explained below. Please take care when submitting personal data to us, particularly 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 personal data.You can always contact us to correct incorrect data (see section 13 below).
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:
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:
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:
D. Personal data we collect from other sources
We may also collect personal data from publicly available sources and third parties, including:
Sony Mobile uses the personal data you provide or which we collect mainly for these purposes:
A. Service provision
B. Product and service development
C. Marketing and advertisement
If you want to know more about our marketing communications, our use of customer profiles and how to opt-out, see section 6 below for more details.
D. Fraud prevention and investigation
E. Other purposes
How is personal data about you shared within Sony and with 3rd 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 consent. However, there are exceptions:
We may disclose personal data 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
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 personal data 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, provide back-up 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.
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.
We may use and/or disclose personal data to third parties
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)
B. Sharing of personal data 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 publicly accessible profile for your account. For example:
Other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content
What are linked Sony accounts and how are they used by Sony group companies?
How does Sony Mobile transfer personal data 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 personal data (including your linked account details – for more information about linked Sony accounts, see section 4 above) 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. Sony Mobile uses a variety of legal mechanisms, including EU Standard Contractual Clauses, 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 which complies with the key data protection principles of fair handling of personal data and ensuring adequate level of protection of personal data.
How does Sony Mobile use your personal data to send you 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:
a. 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:
b. If you use more than one email address to shop or contact Sony Mobile, you will need to unsubscribe separately for each email address
c. This method will only unsubscribe you for emails. You will need to separately unsubscribe for other types of marketing communications you receive
d. 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
e. For managing other types of communication, such as push-notifications in apps, please go the app specific settings to make the changes
As described above, we may create user group profiles or segment data to better understand our customers and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programmes. This processing is based on our legitimate interest to understand our customers better and to provide you with products and services that are better suited to your needs. We may also link or combine personal data to provide you with better personalised services, content, marketing and adverts. When we use customer profiles for direct marketing purposes, you have the right to object to this kind of personal data processing at any time you wish to do so.
Occasionally, we may send you 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 or after sales repair services. These important product and/or service communications are not affected by your marketing communication preferences.
How does Sony Mobile protect your personal data and what can you do to protect yourself?
What are cookies and how are they used?
How can you access your personal data and what are your rights?
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
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 knowingly seek or collect personal data from or about children in contravention of any applicable laws and regulations. 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:
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 13 Contact Us below.
Are there any local or regional differences to Sony Mobile’s personal data handling?
A.California Residents Privacy Rights Notice
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 data pertaining to you related to direct marketing purposes; and b) a description of the categories of the personal data disclosed. Please email your request to us using the details provided in section 13 below.
B.Notice for Australia Residents
In relation to Section 5 “International transfers of your personal data” above, we will disclose your personal data to parties in a number of countries, including Singapore, New Zealand, the United States of America, Japan, the United Kingdom, Sweden, Ireland and Belgium. From time to time we will need to disclose your personal data 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 data.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
Step 2: investigation of complaint
Your complaint will be investigated by our PIM Officer. A response to your complaint will be given in writing within a reasonable period.
Step 3: contact OAIC
We expect that 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
C.Notice for New Zealand Residents
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.
D.Notice for Malaysia Residents
E.Notice for Singapore Residents
Sony Mobile Communications International AB, Singapore Branch 2 International Business Park, #01-10 Tower One, The Strategy Singapore 609930 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.