Privacy Policy for Spatial Audio Video Tool

1. Definitions

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 directly or indirectly by Sony Group Corporation (the term “control” in this context means the direct or indirect ownership of more than 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.

(1) Hosting service provider; and

(2) Customer service provider.

2. What personal data we process

Sony collects and processes data as described below, some of which may be considered to be personal information or personal data under applicable law (collectively, 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)

Notwithstanding the foregoing, the Collected Data does not include data which is or has been fully de-identified or anonymized, including personal data which has been rendered de-identified or anonymous in accordance with legal requirements such that it is incapable of being linked back to or associated with an individual. Sony commits to maintaining de-identified or anonymized data as such and may use such data without restriction.

3. Why we process personal data

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
Provision of functions, features and services of the Application This includes making necessary notifications and providing software updates.	Collected Data listed in Section 2(1)(2)(3)(4)
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, prevention of fraud, security monitoring, regulatory, auditing, investigative purposes	Collected Data listed in Section 2
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, including disclosure of such information in connection with legal proceedings or litigation.	Collected Data listed in Section 2

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 or similar.	We may share some or all of the Collected Data with government authorities 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.
Business transfer	In the event that we undertake a merger, acquisition, reorganization or disposal of all or part of our business, some or all of the Collected Data may be disclosed to any prospective purchaser or acquiring entity and its advisers and will be passed to the new owners of the business.
Professional advisors	In some cases, if this is necessary for the purposes listed above, we may share some or all of the Collected Data under the following categories with professional advisers including lawyers, auditors and insurers.

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 Japan, the US, Canada. 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/regions may not provide the same level of data protection as your country/region. We use a variety of legal mechanisms, including data sharing agreements, to ensure adequate level of protection of the Collected Data. By using the Application, or providing us with any data, you fully understand and consent to this transfer, processing and storage of your data in countries/regions outside your country/region of residence, where the privacy laws may not be as comprehensive as those in the country/region where you reside or are a citizen. Further, courts, law enforcement, and other authorities in countries/regions outside your residence may be entitled to access Collected Data upon its transfer.

6. How long we retain your personal data

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. Where Sony no longer requires the Collected Data, it will be destroyed or de-identified in line with internal Sony information security policies.

7. Policy Regarding Children/Minors

The Application is intended for a general audience; the Application is not directed to and does not knowingly collect personal information from users younger than the age of 16. If you are a parent or guardian and are concerned that your child/minor has provided SONY with personal information (as defined by applicable law), you should contact us as indicated below.

8. Security

Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. We take data security very seriously but we cannot guarantee or warrant the absolute security of any data that we store on our systems or that is stored on our third party contractors’ systems.

9. Changes to this Privacy Policy

Sony reserves the right to make changes to this Privacy Policy and will notify you of any changes by prominently posting notice of the amendment on or within the Application. We may also provide notice to you in other ways, such as through contact information you have provided. You are advised to consult the posted Privacy Policy regularly for any changes.

Your continued use of the Application after the posted effective date will constitute acceptance of, and agreement to be bound by those changes to the extent allowed by law.

10. Contact Information

If you have any questions or concerns about our practices regarding your Collected Data or about this Privacy Policy, please contact us at:

United States:

Sony Electronics Inc.

16535 Via Esprillo

San Diego, CA 92127

Attn: Privacy Office

Telephone: 1-833-681-9900

Email: SonyElectronicsPrivacy@sony.com

Canada:

Sony of Canada ULC.

2235 Sheppard Avenue East, Suite 800

Toronto, ON M2J 5B5

Attn: Privacy Officer, Law Department

Telephone, toll-free (within Canada): 1‑800‑888‑3429

Email: SonyElectronicsPrivacy@sony.com

11. Your Privacy Rights/Jurisdiction Specific Notices:

In some jurisdictions, you have certain rights with respect to the Collected Data that Sony holds about you. These may include the right to request access to the Collected Data and/or you may request that SONY corrects, amends, deletes, erases, destroys, blocks/restrict processing and/or use of such Collected Data. You may also object to SONY’s processing of Collected Data. 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. If you would like to exercise any rights available to you, please contact us as described in “Section 10. Contact Information ”.

(i) Notice to Residents of U.S. States (including but not limited to: VA, CO, CT, MT, IA, DE, UT, TN, TX and OR; but excluding California)

We set forth in our Privacy Policy and Table 1 the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.

Consumers in certain states with comprehensive privacy laws may have the following rights:

If you would like to submit a request to exercise one of the rights listed above, you can do so by completing this form: Data Requests

(ii) Notice to California Residents: California Privacy Notice

This California Privacy Notice is effective as of [insert date of posting] .

This California Privacy Notice supplements our Privacy Policy and sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and any implementing regulations adopted thereunder (“CPRA”). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.

California Consumer Rights. Subject to certain exceptions, as a California consumer, you may have the following rights regarding your Personal Information:

Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under applicable state law. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.

Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We will only use the information you provide in a request to verify your identity.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify your identity, we will not be able to process the request.

Exercising Your Rights.

Right to Know; Right to Delete; Right to Correct.

If you are a California Consumer and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please submit your request at: Data Requests; or you may call us toll-free at 1-833-681-9900.

Data Retention.

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. Where Sony no longer requires the Collected Data, it will be destroyed or de-identified in line with internal Sony information security policies.

Data Reporting.

Click here to access our data reporting metrics for the previous calendar year.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.

California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will not discriminate against you for exercising your CPRA rights.

Notice of Financial Incentive.

Under California regulations, if we offer certain loyalty or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a “financial incentive”. In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.

Personal Information We Collect & Purposes for Collection.

The Personal Information we collect about you will depend upon how you use the Application. Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by applicable law.

We may have used Personal Information for the business or commercial purposes described in Table 1:

[Table 1]

Categories of Personal Information Collected	Purposes for Collection of Personal Information	Who We Share Personal Information With for a Business Purpose	Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising
Identifiers: Such as: Email address, phone number, your name, postal code, online identifier such as IP address; Device ID, Android Advertising ID, Identifier for Advertisers	Provision of functions, features and services of the Application Protecting the interests of Sony Group Companies and users Compliance with law	SONY Affiliates IT Service Providers Hosting Service Providers Business transfer recipients Customer service providers Government Authorities/ Law Enforcement Officials Auditors and external consultants (e.g. lawyers, tax accountants)	N/A
Any categories of personal information described in subdivision (e) of Section 1798.80*   Such as: name, contact information, government identifiers; financial information and online or device identifiers such as Device IDs, IP address, Advertising ID.   *Some of this information may also be included in other categories of information	Provision of functions, features and services of the Application Protecting the interests of Sony Group Companies and users Compliance with law	SONY Affiliates IT Service Providers Hosting Service Providers Business transfer recipients Customer service providers Government Authorities/ Law Enforcement Officials Auditors and external consultants (e.g. lawyers, tax accountants)	· N/A
Internet or Other Electronics and Network Information: Such as: usage status and usage history of Application, Installed Device and Related Devices	Provision of functions, features and services of the Application Protecting the interests of Sony Group Companies and users Compliance with law	SONY Affiliates IT Service Providers Hosting Service Providers Business transfer recipients Customer service providers Government Authorities/ Law Enforcement Officials Auditors and external consultants (e.g. lawyers, tax accountants)	· N/A

For more information about our local SONY electronics affiliate’s California privacy practices, please refer to this California-specific information here: Calif. Privacy Notice

Additional Notice to California Residents:

If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to which we may have disclosed, within the past year, personal information pertaining to you and your family for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to SonyElectronicsPrivacy@sony.com, and include your name, email address, mailing address or zip code, and a reference to “Your California Privacy Rights –.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information. 

(iii) Notice to Nevada Residents

If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. SONY does not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if SONY were to engage in such a sale in the future, you may submit your request in writing to: SonyElectronicsPrivacy@sony.com. Your request must reference “Your Nevada Rights – Spatial Audio Video Tool” and include your name, mailing address, zip code, and email address. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. We will respond to valid requests within 60 days.

(iv) Further Information for Residents in Québec, Canada

This notice sets forth disclosures and rights for consumers residing in Québec, Canada regarding their personal information, as required by the Québec’s Data Privacy Law 25. All SONY personnel handling personal information will be subject to a duty of confidentiality and to ensure that all personal information is handled in accordance with standard security measures. By using the Application, you acknowledge and agree that your personal information will be transferred outside of Quebec.

We will only use your personal information for the purposes stated at the point of collection, or as otherwise noted in this privacy policy.

Automated Decision Making.

SONY does not use personal information to render any decisions based exclusively on an automated processing of such information.

Location Tracking.

We may use automated technologies to collect information about your general location, such as your country/region. However, we do not track your location without your consent.

Consumer Rights.

Subject to certain exceptions, you may have the following rights regarding your personal information:

You may also ask us to clarify the categories of persons that have access to your personal information and the applicable retention period.

Exercising your rights.

If you are a Quebec resident and wish to exercise your right(s) listed above, please submit your request here: SOCAN Privacy Request Webform; or you may call our toll-free (within Canada) number 1‑800‑888‑3429.

Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.

Our Privacy Officer is in charge of the protection of personal information.

Contact information for SONY’s Privacy Officer.

Sony of Canada ULC,

Attn: Privacy Officer, Law Department

2235 Sheppard Avenue East, Suite 800 Toronto, ON M2J 5B5

Telephone: 1‑800‑888‑3429 (toll free within Canada)

Email: SonyElectronicsPrivacy@sony.com

You may submit a complaint to the Commission d’accès à l’information du Québec (CAI) by visiting: https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.