PRIVACY POLICY FOR SONY AUDIO PRODUCTS

This Privacy Policy applies to SONY’s audio products or devices, including wireless speakers, home theater products and audio systems (“Device”).

In this Privacy Policy, we use “SONY,” "we," "us," and "our" to refer to Sony Corporation. “SONY Affiliates” shall mean Sony Group Corporation, which is the ultimate parent company of SONY and any legal entities controlled by Sony Group Corporation. SONY and SONY Affiliates shall be collectively referred to as “SONY Group”. 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.  SUMMARY OF KEY POINTS

2. What information do we collect?

SONY collects and uses information or data as described below. Some of this information may be considered personal information under applicable law in your jurisdiction (collectively, the “Collected Data”).

Information collected automatically from the Device:

The Collected Data as described above will be uploaded with a unique number assigned to the Device and will allow SONY Group to distinguish the data received from the Device from those received from other devices.

3. How does SONY use the Collected Data?

(i) Providing the features and function of the Device to you.

SONY may use the Collected Data in order to provide you with certain functions and features of the Device and respond to your inquiries.

(ii) Improving/developing SONY’s products and services

SONY uses the Collected Data to improve and develop SONY’s current and future products and services. Product improvement and/or development includes those relating to either an improvement of the technical functions of the Related Device or the usability of such product for user’s convenience. Such product improvement /development is only done with information that does not identify you personally, using aggregated and/or anonymized data.

SONY Affiliates may access and use the Collected Data for internal business purposes and to improve and develop SONY’s current and future products and services as well, however only in an aggregated/anonymized, i.e. non-personal manner.

4. Who else has access to the Collected Data?

We do not share personal information with third parties for their own marketing purposes but we may share non-personal information, including aggregate data and de-identified data, with third parties to the fullest extent allowed by law. In addition, SONY may share Collected Data with SONY Affiliates and third parties as follows:

SONY Affiliates

Aggregated/anonymized or non-personal Collected Data may be shared with and used by other SONY Affiliates for internal business purposes and for product improvement and development. SONY may otherwise share Collected Data with SONY Affiliates for other purposes set out in this Privacy Policy.

Service Providers

SONY and SONY Affiliates may use third party service providers to process or analyze the Collected Data on their behalf for the purposes set out in this Privacy Policy. Such third parties include, but are not limited to, IT service providers and data hosting providers.

Business transfer

In the event that SONY or a SONY Affiliate sells or transfers a portion or all of its business, the Collected Data may be transferred by SONY or such SONY Affiliate to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer.

Compliance and enforcement

SONY may retain, use and/or disclose any of the Collected Data if required or permitted by law, regulation or order or if required for us to protect our legitimate interests, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend itself, or others, against illegal, criminal or harmful activities.

Other Unaffiliated Third Parties

We may disclose Collected Data to auditors or similar external consultants like lawyers or tax advisors, to defend and exercise our legal rights (e.g. enforcing compliance with the terms of use) and as we believe necessary to comply with our legal obligations.

5. Data Retention

SONY will collect the Collected Data described in Section 2 for as long as you use the Device and such Collected Data will be deleted within twenty-seven (27) months from the date of such collection.

Notwithstanding the foregoing, 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. Transfer of the Collected Data internationally

The Collected Data may be processed, stored and transferred for the purposes outlined in Section 3 to countries outside your country of residence, including in particular Japan and the United States. By using the Device, or providing us with any information, you fully understand and consent to this transfer, processing and storage of your information in the United States, Japan, and other jurisdictions, where the privacy policy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

7. Security

SONY undertakes reasonable security measures designed to protect against the loss, misuse or alteration of the Collected Data. Although SONY strives to protect the Collected Data, SONY cannot guarantee or warrant the security of any Collected Data transmitted to SONY through the Device or that SONY stores on its systems or that is stored on SONY’s third party service provider' systems.

8. SONY’s Policy Regarding Children

SONY Group is committed to complying with all applicable laws and regulations regarding the collection, storage and use of the Collected Data concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries. This Device is intended for a general audience; this Device is not directed to and does not knowingly collect personal information from children under the age of 16. If you are a parent or guardian and are concerned that your child has provided a SONY Affiliate with the Collected Data without your consent, you should contact such SONY or SONY Affiliate as indicated below.

9. Changes

SONY will notify you of any changes to SONY’s Privacy Policy by posting the new Privacy Policy here http://policies.sony.net/vs/01/index.html and by prominently posting notice of the amendment on the display of the Device or the application which you use with the Device. You are advised to consult the posted Privacy Policy regularly for any changes.

10. Notice to California Residents/Other State Rights:

California Privacy Notice

If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

CA Personal Information. Consistent with Section 2 above, we may collect certain categories of information about California residents that may be considered “personal information” (“CA Personal Information”) as defined by the California Consumer Privacy Act (“CCPA”) for the purposes described in this Privacy Policy, specifically:

Identifiers: Such as Device ID and IP address;

Internet or other electronic network activity information: Such as operational status and setting information of the Device, usage status and usage history of the Device, and specifications of content.

Sources of CA Personal Information. Consistent with Section 2 above, we may collect CA Personal Information from your Device.

CA Personal Information Disclosed For Business Purposes.

California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information: (i) Access. Request access to your CA Personal Information that we collect, use, or disclose; (ii) Deletion. Request deletion of your CA Personal Information; provided that to the extent permitted by applicable law, we may be required to retain some of your CA Personal Information; and (iii) CA Personal Information Disclosed For Business Purposes. Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months.

Exercising other California consumer rights. If you are a California resident and wish to exercise any of these rights or if you have questions regarding the Information collected or shared with third parties, please: (a) email us at: privacy@am.sony.com, with the specific nature of your request, referencing “Your California Privacy Rights – Home Audio”; or (b) call the following toll-free number 1-833-681-9900. When submitting your request, you must include your first and last name, email address, and zip code or mailing address. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that you are limited by law in the number of requests you may submit per year. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your CA Personal Information.

Authorized Agents: To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

Access Notice in Alternative Formats. Consumers who need assistance accessing the notice in alternative format can do so by emailing us at: privacy@am.sony.com

11. Contact Information

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have with respect to your personal information, please contact us at:
Sony Electronics Inc.
115 West Century Rd., Suite 250
Paramus, NJ 07652
Attn: Privacy Office

Telephone: 1-833-681-9900
Email: privacy@am.sony.com


Effective Date: This Privacy Policy is effective as of April 21, 2021.


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