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    Sony Mobile Privacy Policy

    This Privacy Policy was last updated in May, 2018, prior policies are archived here

    Overview

    Your privacy and trust are important to us. This Privacy Policy explains the types of personal information and data (hereinafter “personal data”) that we may collect and hold, how that personal data is used and with whom the personal data is shared. You will find contact information at the end of this Policy if you have any queries or concerns.
    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 centers made available to you. Sony Mobile is responsible for ensuring that the processing of personal data complies with this Policy.
    Our products and services evolve constantly and we will adjust this privacy policy to accurately describe what personal data we process, how we process it, and with whom we are sharing the personal data, as well as, if required, to comply with changes in applicable laws or for legitimate business purposes. If we make changes to this policy, we will change the last-updated date (see top) and update this page. If we make material changes, we will let you know either by putting a notice on our website or by directly informing you about the changes. Please check from time to time what changes we have made.
    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 recognize 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 authorized 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 centers 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 programs, we may collect personal data relating to your use of the loyalty program 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 personalize 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 cart
    • 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 behavior, 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

    For more information and for details about how you can control access to your social network profile, you should view the privacy policy and other guidance available on your social network’s website. 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 Center, 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 authorized fulfillment 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

    B. Product and service development

    • 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

    C. Marketing and advertisement

    • 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 personalize 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 programs, which we may share with third parties, and/or make available to the public
    • show you personalized content, recommendations, and advertisements. You may notice this personalization when you use Sony Mobile products and services, when we send you marketing communications, and when you visit our own 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. Some of the personalization that you see on our websites or in our online advertisements make use of cookies set by us or our third-party advertising partners. Please see our Cookie Policy for more information. In other cases, our applications and services may have specific settings to control personalized content; you should consult the applicable terms and conditions of the relevant application or service for more information
    • use product reviews, comments, or content you have uploaded and made publicly visible in our websites or services to link to, publish, or publicize 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, the time and date of your post or thread, and 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
    • 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

    • 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.

    E. Other purposes

    • 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 centers. 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, personalized services, content, marketing, and adverts. If you want to know more about our use of customer profiles, see section 6 below for more details.

    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
      • you use your Sony Mobile devices and/or applications or services to access, purchase, or download content, services, applications, or products that are published, developed, supported, or offered by other Sony group companies. They may combine this personal data with other details they hold about you. Unless they provide you with their own privacy policy, they may use your personal details for the purposes explained in this Privacy Policy. Where you have multiple accounts with different Sony group companies, these Sony group companies may also share personal data with us in accordance with their own privacy policies; 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 authorized data processors). Examples of authorized data processors could include billing and fulfillment 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 personalize content, fulfill 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 authorized 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 Where you download and/or use any Sony Mobile applications and/or services that include third party advertisements (whether featured within the application or service itself or displayed to end users using a frame, wrapper, pop-up, or any other form of advertising functionality), we may share personal data we collect about your usage of the applications and services with our advertising partners so that they can better target and / or personalize advertisements displayed within any Sony Mobile service or application used by you. Some of our third-party advertising partners act independently, and thus will handle shared data under the terms of their own privacy policies. When such sharing occurs, our applications and /or services will notify you when you first activate the application and/or service. Additionally, you can control personalized ads in your browser’s cookie settings (for more information, see our Cookie Policy) and in your Android device via the Settings menu (Settings -> Google -> Ads).
    • 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)

    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? 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 synchronized across your linked accounts so you can more easily manage your accounts. This Privacy Policy applies to our use of personal data relating to your linked account(s) and your use of our applications and services. Other applications and services from Sony are operated by different Sony Group companies. The privacy policy of each service will tell you how your account details will be used in connection with that service, as well as which Sony Group company is responsible (you can find the privacy policy for a service on its website). However, Sony group companies may generally use personal data relating to your linked Sony accounts for the following purposes:

    • Linking accounts/synchronized 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 synchronized, 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 center 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, offers, and information about competitions, 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 analyzed 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)

    After you have linked your accounts, the Sony group company operating each service you are accessing will continue to control your account for that service (and any data collected when you use that service) in accordance with its privacy policy. Linking your accounts does not change this. If you wish to exercise any personal data rights (such as your right of access) in connection with an individual account, you will need to contact the relevant Sony Group company controlling the account using the details given in its privacy policy. In the event that you wish to cancel or terminate some or all of your linked accounts, you will need to follow the account cancelation 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 finalize account cancelation requests for their own particular 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 organization. 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 authorized 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?

    1. Marketing communications
    2. When you provide us with contact details, such as when you purchase a product, contact our customer support call centers, 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 example, details about the latest Sony products and services, including upgrades and special offers that may interest you. 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

    3. Customer profiles
    4. 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 programs. 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 personalized 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.

    5. Important information and service messages
    6. 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 fulfill 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 unauthorized access will never occur, rest assured that Sony Mobile takes great care in maintaining the security of your personal data to prevent unauthorized access to it, through the use of appropriate technology and internal procedures. We take a number of steps to protect your personal data from unauthorized 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 or 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
    • Does this Privacy Policy extend to third party websites visited when following links on our website(s)?
      • 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? 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 then recognize your browser the next time you visit our websites. Cookies allow us to customize your experience to better match your interests and preferences, or to simply facilitate your sign in process when using 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 customization settings you have previously specified, and our ability to personalize your online experience would be limited. Please refer to your browser instructions to learn more about these functions. More information about our use of cookies can be found in our Cookie Policy. 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 https://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.

    9. Access to your personal data and your rights

    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. Please understand that if you request us to remove your personal data, you may not be able to use all of our products and services. Certain personal data is strictly necessary in order for us to fulfill the purposes described in this Privacy Policy. Sony Mobile may also be required to retain some personal data by applicable laws, in which case you may not be entitled to remove it. 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 to your national or any other data protection authority.

    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 If you would like to make a complaint, let us know by contacting our PIM Officer at Australia.privacy.sonymobile@sony.com or use the details set out in section 13 Contact Us below. 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 Web: oaic.gov.au 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

    In view of the implementation of the Personal Data Protection Act 2010 (“Act”), Sony Mobile recognizes the need to process all personal data obtained in a lawful and appropriate manner. The legal responsibility for compliance with the Act lies with Sony Mobile, which is the “data user” under the Act. Compliance with this Privacy Policy and the Act is the responsibility of all employees of Sony Mobile. As and when Sony Mobile is required to collect personal data, Sony Mobile and its employees must abide by the requirements of this Privacy Policy and the Act. In the context of the Act, “processing” is defined as including the collection, recording, holding, or storing of personal data which includes, inter alia, NRIC numbers, home address, and contact details. A data subject has the following rights under the Act:

    • 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.

    Any individual who intends to exercise the abovementioned rights or has any enquiries regarding this Privacy Policy should make a written request to Sony Mobile at Malaysia.privacy.sonymobile@sony.com or use the details set out in section 13 Contact Us below. Sony Mobile will generally be able to respond to such queries and/or requests within 30 days.

    E.Notice for Singapore Residents

    Sony Mobile collects, uses, discloses, manages, and handles Personal Data that is subject to the Personal Data Protection Act 2012 (No. 26 of 2012) (“the Act”). Please read this Privacy Policy carefully. By accessing our website, using any services provided by Sony, signing up for any products and services provided by Sony, submitting any information to us or otherwise showing your agreement thereon, you will be deemed to have agreed and consented to the terms of this Data Protection Policy. “Personal Data” means any data, whether true or false, which can be related to a specific identifiable individual, whether such individual is identifiable from the data itself, or from other information that is available to Sony Mobile. Personal Data includes the personal data collected, used, disclosed, managed, and handled in accordance with this Privacy Policy. If you (a) have any questions or feedback relating to your Personal Data or our Privacy Policy, (b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy or otherwise or (c) would like to gain access or make corrections to your Personal Data records, please contact Sony Mobile as follows:

    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.

    13. Contact us

    How can you contact Sony Mobile about your personal data? If you need further assistance or would like to make a comment, please Contact us online or at: Data Protection Officer Sony Mobile Communications AB 221-88 Lund, Sweden https://www.sonymobile.com/us/legal/privacy/