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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
1. Personal data that we collect
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:
- 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 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 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 personal data 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 customer service calls and keep personal data about the particular communication, where this is permitted by applicable law. The personal data collected may include 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 programmes, we may collect personal data relating to your use of the loyalty programme and the rewards you claim
- When you enter our retail or repair facilities, your image may be recorded by our security cameras
- When you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for personal data, 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. 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 an internet-enabled product 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(including any advertisements) 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. For example, when you use our websites, we may collect personal data 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 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
- Device Information such as your device ID(s), 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. Your device ID is also collected, when you download a software update
- With your explicit consent, personal data related to your physical behaviour, health and biometric data such as voice authentication data, fingerprint or facial characteristics or features
- 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 click on a ‘like’, ‘+1’, ‘tweet’ or similar button on 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 personal data 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 personal data about your social network profile, depending on your social network account privacy settings
D. Personal data we collect from other sources
We may also collect personal data from publicly 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, 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 and what is the legal basis for processing this personal data?
Sony Mobile uses the personal data you provide or which we collect mainly for these purposes:
A. Service provision
- When we are using personal data to offer our products and services to you, the processing is based on a contract between you and Sony Mobile. We may use personal data to:
- provide you with a product or service you have requested, including any back-up and restore service
- provide you with software updates which may contain critical security and functionality patches that make your device more secure and protect the personal data on the device
- facilitate and process your searches and requests for information when you contact us about Sony Mobile and its products and services
- provide our checkout assistance service. When you use our applications and services including any online e-commerce stores, such as the 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 that prevented you from completing a 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
- We work constantly to make our products and services better. We base this processing on our legitimate interests to develop our products and services, to better meet customer requirements, to ensure quality, to develop identity management, 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
- ask for your opinions on Sony Mobile products and services and conduct product surveys
- 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
- When we use personal data for marketing purposes, we base the processing on our legitimate interests to know our customers, keep you up-to-date about Sony Mobile's latest products and services and to personalise your customer experience. In some cases, we base marketing on your prior consent, e.g. for sending marketing messages. We may use the personal data we collect and/or any personal data about you which is shared with us for marketing purposes, e.g. from other Sony group companies whose products, applications and services you also use. In particular, we may:
- 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, text message (SMS) or other means, if you have consented or if we are otherwise permitted to do so under applicable law
- ensure that you benefit from any relevant special offer or promotion
- hold prize draws, contests and other promotional offers
- create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programmes, which we may share with third parties and/or make available to the public
- 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, including in our own marketing. 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
- Sony Mobile may use personal data to prevent fraud and to investigate violations or our policies. For example, we may use your device information such as your device ID(s) to ensure that any vouchers or discounts relating to any promotions or campaigns are not being redeemed fraudulently, and to check that a payment is not made fraudulently. In this case, we base the processing of personal data on our legitimate interest to prevent fraud and to provide benefits only to our customers. We may also 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. In this case, we base the processing on a legal obligation to which Sony Mobile is subject or on our legitimate interest to defend our legal rights.
- We may use your personal data for other purposes:
- for staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other customer support centres. We base this processing on our legitimate interest to ensure the quality and efficiency of our customer service
- if we consider employing you if you contact us via one of Sony Mobile’s job application websites. This processing is based on your consent and we provide additional information about data processing in recruitment on our recruitment websites
- 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). This processing is based on our legitimate interest to provide a better customer experience and service. 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), to allow us to provide more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts. If you want to know more about our use of customer profiles, see section 6 below for more details.
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
3. Sharing personal data about you
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:
- Other Sony group companies
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
- You use other Sony group company’s products or services and have shared personal data with them previously. In such circumstances, we may combine all of Sony’s data about you and use it in accordance with our respective Privacy Policies.
- 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); or
- Sony Mobile transfers a portion or any part of our business to another Sony group company
- Sony Retail Stores
If you choose to purchase Sony Mobile products or services from a Sony retail store (whether in-store, through our website or over the telephone), your purchase information may be shared by Sony Mobile with that Sony retail store. Your purchase information may be combined with other data that Sony retail store 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 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.
- 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 personal data to third parties
- 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
- 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
- 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 partners, advertisers, industry bodies, the media and/or the general public)
- Anonymous statistics
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:
- 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
4. Linked Sony accounts (“One Sign In”)
What are linked Sony accounts and how are they used by Sony group companies?
- 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 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)
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 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.
6. Marketing communications and how to change your preferences
How does Sony Mobile use your personal data to send you communications and how can you change your marketing preferences?
- Marketing communications
- Customer profiles
- Important information and service messages
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.
7. Security of your personal data
How does Sony Mobile protect your personal data and what can you do to protect yourself?
- What we do to protect your personal data
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 personal data from unauthorised access, use or alteration and unlawful destruction and disclosure, including where appropriate:
- Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive personal data, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us)
- Limiting access to the personal data we collect about you (for instance, only those of our personnel who need your personal data to carry out our business activities are allowed access)
- Putting in place physical, electronic and procedural safeguards in line with industry standards
- What should you consider regarding sharing content and links via Sony Mobile's applications?
- 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 in 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 breach someone else’s privacy is prohibited. Encouraging or asking users to publicly disclose their personally identifying information is also prohibited
- What you should do to protect your personal data
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
- 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
8. Cookies & Tracking
What are cookies and how are they used?
9. Access to your personal data and your rights
How can you access your personal data and what are your rights?
10. Retention of 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
11. 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 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:
- 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 13 Contact Us below.
12. Local or Country-Specific Notices
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
- 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;
- Prevent data processing that is likely to cause distress or damage;
- Take reasonable action to stop the use of, rectify, erase and/or dispose of inaccurate personal data; and
- Withdraw consent given to Sony Mobile.
E.Notice for Singapore Residents
- Email: Singapore.email@example.com
- Write in: Data Protection Officer
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.