Privacy Policy for Spatial Audio Video Tool
Last Updated: [2026-10]
This Privacy Policy sets out how Sony Corporation, of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan (“Sony”, “we”, “our” or “us”) collects, uses, stores and otherwise processes Collected Data (defined below) in relation to the use of “Spatial Audio Video Tool” mobile application (the “Application”).
It also describes your data protection rights, including the right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 “Privacy Rights” below.
Table of Contents
2. What personal data we collect
3. Why we process personal data
4. With whom we share Collected Data
5. Where we transfer Collected Data
6. How long we retain your personal data
1. Definition
1.1 “Collected Data” has the meaning set forth in Section 2 below.
1.2 “Sony Group Company” means Sony Group Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony Group Corporation (the term “control” in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity).
1.3 “Service Provider” means any third party who processes personal data on behalf of Sony, including but not limited to hosting providers, analytics service providers and customer support providers.
2. What personal data we collect
Sony collects data as described below, which may include personal data (collectively, the “Collected Data”). For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of “Controller” and “Processor” are defined, Sony is the “Controller” of the Collected Data.
(1) Unique identifier of the Application
(2) Application version
(3) Device model name, Operating System version and setting information (e.g. language; country or region)
(4) IP address
(5) Specific usage information of the Application (e.g., logs regarding the operation of each function of the Application including timestamps)
<Collection method>
Sony collects the above information automatically when you use the Application.
3. Why we process personal data
3.1 Sony processes your Collected Data for the purposes as described below. For these purposes, Sony may use Collected Data in conjunction with the information collected through other Sony Group Companies’ products and services if you use one of those.
| Purpose | Category of Collected Data | Legal Basis |
| Provision of functions and/or services of the Application to fulfil a contract with you To deliver functions and/or services you have asked us to provide to you. This includes making necessary notifications and providing software updates. | Collected Data listed in Section 2(1)(2)(3)(4) | The processing is necessary to perform a contract or to take steps, at your request, prior to entering into a contract with you. |
| Enhancement of our products, services and business based on statistical data To analyse your use of the Application in order to improve and develop Sony Group Companies’ products, services and business. | Collected Data listed in Section 2(2)(3)(5) | We have a legitimate interest in understanding how our products and services are used, to learn what business strategies are effective and to improve them. |
| Protecting the interests of Sony Group Companies and users To protect Sony Group Companies’ business interests and legal rights and the interests and legal rights of our users. This includes the use of Collected Data in connection with legal claims, compliance, regulatory, auditing, investigative purposes (including disclosure of such information in connection with legal proceedings or litigation). | Collected Data listed in Section 2 | We have a legitimate interest in protecting Sony Group Companies’ business interests and legal rights, and the interests and legal rights of our users. |
| Compliance with law To respond to requests from and, where required, report content to government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws. | Collected Data listed in Section 2 | When we have a legal obligation under EU/UK laws: We process Collected Data in order to comply with applicable law and regulations. When we have a legal obligation under laws outside the EU/UK: We have a legitimate interest in protecting Sony Group Companies’ business interests and legal rights, and the interests and legal rights of our users. |
3.2 Where we collect the Collected Data to perform a contract with you, or where we have to collect Collected Data by law, provision of this data is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of any requested Collected Data is optional, but not providing information may affect your ability to use the services or use particular aspects of the services if information is needed for those purposes.
3.3 There are instances where we have a legitimate interest to use the Collected Data. Our legitimate interest will vary depending on what we are using the Collected Data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process the Collected Data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
4. With whom we share Collected Data
Sony shares your Collected Data with the following entities.
| Entities with whom we share Collected Data | Detail |
| Sony Group Companies | We share Collected Data with Sony Group Companies where those companies process it on our behalf to provide products and services to you. <Categories of Collected Data> Collected Data listed in Section 2 |
| Service Providers | We share Collected Data under the following categories with Service Providers, including Sony Group Companies. <Categories of Collected Data> Collected Data listed in Section 2 |
| Government authorities, law enforcement officials, regulators, and court and similar. | We may share some or all Collected Data under the following categories with government authorities and/or law enforcement officials if required by law, or if necessary for us to protect our legitimate interests, or the interests of others, in compliance with applicable laws. <Categories of Collected Data> Collected Data listed in Section 2 |
| Counterparty of Business transfer | In the event that we undertake a merger, acquisition, reorganization or disposal, some or all Collected Data under the following categories may be disclosed to any prospective purchaser and/or its advisers and will be passed to the new owners of the business. <Categories of Collected Data> Collected Data listed in Section 2 |
| Professional advisors | In some cases, if this is necessary for the purposes listed above, we may share some or all Collected Data under the following categories with professional advisers including lawyers, auditors, or insurers. <Categories of Collected Data> Collected Data listed in Section 2 |
5. Where we transfer Collected Data
We will process, store and transfer Collected Data for the purposes outlined in this Privacy Policy from your country/regions of residence globally to countries/regions outside your country/region of residence. Collected Data will be processed by staff operating outside your country/region of residence who work for us or for one of our Service Providers. Some of the countries and regions may not provide the same level of data protection as your country/region.
For EEA/UK Individuals: Sony takes appropriate measures to ensure that all transfers of Collected Data outside of the EEA/the UK meet the requirements of applicable EU and UK data protection legislation. Where information is transferred outside the EEA and the UK, where the privacy laws may not provide an equivalent level of protection to those in your home country/region and where this is to a stakeholder or vendor in a country/region that is not subject to an adequacy decision by the EU Commission or the UK Government, the personal data is adequately protected by the vendor's EU / UK Processor Binding Corporate Rules, the EU Commission’s approved standard contractual clauses which can be accessed here or the addendum to the EU Commission’s standard contractual clauses or standalone international data transfer agreement approved under UK data protection law (as applicable). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
6. How long we retain your personal data
6.1 Sony will keep the Collected Data for as long as it is necessary for the relationship with you and the purposes detailed in Section 3 or otherwise permitted or required under applicable law. Sony may retain Collected Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Collected Data for specific periods.
6.2 If there is a claim or a potential claim, or if we are required to retain information by law then we will keep the data for so long as is reasonably necessary for this.
7. Children
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of Collected Data concerning children. The Application is not directed to and does not knowingly collect Collected Data from children. Depending on your country/region of residence, this threshold age for a child may differ. If you are a parent or guardian and are concerned that your child has provided us with Collected Data without your consent, you should contact us as indicated in Section 10 “Contact Information” below.
8. Privacy Rights
8.1 In some countries/regions, you have the following rights with respect to Collected Data Sony processes about you:
(1) Ask us for a copy of Collected Data
(2) Ask us to correct, delete or restrict our processing of Collected Data
(3) Request us to transmit some Collected Data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible
(4) Object to our processing Collected Data on the basis of our legitimate interests (or those of a third party)
(5) Where we have asked for your consent, to withdraw consent at any time. If you ask to withdraw your consent, this will not affect any processing which has already taken place at that time.
8.2 You can exercise these rights by contacting us as indicated in Section 10 “Contact Information” below. These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
8.3 If you have unresolved concerns, you have the right to complain to a data protection authority in the country/region where you live, work, or where you believe a breach has occurred. Details of EU data protection authorities is available here and the website of the data protection authority of the UK Information Commissioner’s office is here.
9. Changes to this Privacy Policy
This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (if necessary under applicable law) of any changes to this Privacy Policy.
10. Contact Information
10.1 The data controller for Collected Data is Sony Corporation of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan. If you have any questions or concerns about this privacy policy or if you wish to exercise any legal right you have in respect of Collected Data, you can contact local Sony Group Companies using the contact details that can be found at https://www.sony-europe.com/.
10.2 Sony’s representative in the European Economic Area and Switzerland is Sony Europe B.V. They can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe B.V. at Taurus avenue 16, 2132LS Hoofddorp, the Netherlands.
10.3 Sony’s representative in the UK is the UK branch of Sony Europe B.V. who can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe B.V. (UK branch), The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.