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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
A. California Residents Privacy Rights Notice
B. Notice for Australia Residents
C. Notice for New Zealand Residents
D. Notice for Malaysia Residents
E. Notice for Singapore Residents
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.
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
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:
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
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.
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:
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.
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?
You may be able to link your accounts for different Sony applications and services so you can use the same sign in details (email address and password) to access them all (“One Sign In”). Other basic account details may also be synchronised across your linked accounts so you can more easily manage your accounts.
However, Sony group companies may generally use personal data relating to your linked Sony accounts for the following purposes:
In the event that 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.
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:
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 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?
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.
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 data about your online activities over time and across different websites when you visit our websites or other online websites and services.
How can you access your personal data and what are your rights?
You have a right to access personal data we hold about you. If you think your personal data is inaccurate or incomplete, you have the right to request us to correct or delete it. You may also request us to update or change personal data at any time. You have a right to object to certain types of processing, such as marketing. You also have a right to data portability, i.e. the right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.
You can exercise these rights by contacting us using the details given in section 13 Contact Us below. You may be asked to provide some proof of identification so that we can verify that it is you making the request. Subject to applicable law, we reserve the right to charge a fee (subject to any cap on fees as required by applicable law) for inspection of your personal data held by us. If you think Sony Mobile is not handling your personal data appropriately, you have the right to file a complaint in your national or any other data protection authority.
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 3 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 3 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?
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 personal data disclosed. Please email your request to us using the details provided in section 13 below.
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:
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.
A data subject has the following rights under the Act:
Sony Mobile Communications International AB, Singapore Branch
2 International Business Park, #01-10 Tower One, The Strategy
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.