Effective: June 24th, 2020
1. Collection of Information
1.1 Information You Provide To Sony
While Sony does not generally require that you provide us with personally identifiable information in order to visit our Website, please note that in order to participate in some activities, such as signing up for an account, purchasing a product, or participating in sweepstakes, contests and other promotions (collectively, “Promotions”), we may ask you to provide information that identifies you as a specific individual (such as first and last name, address, e-mail address, mailing address and telephone number) (“Personal Information”). We may also ask you to provide other information about yourself, such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. If you choose not to provide such Personal Information or other information to us, you may not be able to participate in certain activities we offer. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information. We may also de-identify, aggregate or anonymize Personal Information, turning it into non-Personal Information. This is sometimes accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.
Individuals Younger Than Age 16. (For US residents)
The Website is directed to a general audience and we do not target. users under the age of 16.
If we become aware that we have collected personal information from a child under the age of 16 in contravention of any applicable laws or regulations, we will delete that personal information from our files promptly.
Any parent or guardian with questions regarding the collection or use of personal information relating to their child should contact us using the details provided in the Contact Us section below.
1.2 Information Sony Collects Automatically
In addition to any Personal Information or other information that you choose to provide to us via the Website, whenever you visit or interact with the Website, Sony automatically collects certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access the Website and any referring website. (A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) We may directly collect specific location information from your Device if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Website.
In addition, Sony, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the Website (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if Sony associates it with you as a specific and identifiable person, we will treat it as Personal Information.
1.3 Cookies and Other Tracking Technologies.
The technologies used on the Website to collect Usage Information, including Device Identifiers, may include the technologies described below. You may be able to disable cookies and similar technologies by adjusting your browser settings to disconnect the link between cookie information and non-personal viewing information generated by those technologies.
The methods used to collect Usage Information may include the following:
Cookies & Local Storage. “Cookies” (which may be html files, Flash files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit the Website or otherwise access our online content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Website may make use of this local storage. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies Flash cookies, and other local storage devices may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your experience. You may refuse or remove some or all of these cookie and local storage technologies; however, if you choose to do so, some features of our Website may not function properly.
Web Beacons. “Web beacons” (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Website, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
1.4 Social Media Applications
Functionality on the Website may permit interactions between the Website and a third-party website, such as enabling you to “like” a product or “share” content to third-party websites. If you choose to “like” or “share” content or to otherwise post information from or via the Website to a third-party website, feature or application, that information may become public and the third-party web site may have access to information about you and your use of the Website.
2. Uses of the Personal Information Sony Collects
Sony will use the information it collects, including your Personal Information:
• to tailor your experience on the Website;
• to process your purchases of products or services from us;
• to determine which products and services we offer may be of interest to you;
• to allow you to participate in the Website and features offered through the Website;
• to process your registration with the Website, including verifying that your email address is active and valid;
• to send you special offers from us, our advertisers, or third-party business partners;
• to allow you to participate in the public areas and other features of our Website;
• to tailor content, recommendations, and offers we display to you, both on the Website and elsewhere online;
• to provide you with customer service, support and answer questions or other requests; and
We may also use the information we collect to improve the Website and our products and services, for internal business purposes, to comply with regulatory and legal obligations, to prevent fraud and manage the security of the Website, and to contact you with regard to your use of the Website and, in our discretion, changes to any of our policies.
3. When and With Whom Sony May Share Information Collected
We may share de-identifie or anonymized information, such as aggregate user statistics, demographic information, and Usage Information with third parties as permitted by law.
We may also share your Personal Information, as specifically disclosed at the time you provide your Personal Information and in the following circumstances:
To Other Sony Companies.
To Third-Party Service Providers Providing Services On Sony’s Behalf.
We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your Personal Information with third party service providers that assist us with providing content, processing transactions, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Sony. As one example, if you access content or services that are published, developed or supported by a third party, your Personal Information may be shared with that third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information in order to host or operate the Website, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.
When You Consent To Have Your Personal Information Shared or Otherwise Request That We Share Your Information.
We may share your Personal Information with other entities affiliated with us for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. In addition, Sony or any of its assets, including the Website, may be sold, or other transactions or transitions may occur whether voluntary or involuntary (such as through bankruptcy) in which your information, including your Personal Information, is one of the key business assets in the transaction. In such a case, your Personal Information may be one of the business assets we transfer. Hence, Sony reserves the right to disclose and transfer user information, including Personal Information, in connection with any activity and/or transaction described above. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
Legal Protections and Law Enforcement.
We may transfer and disclose information, including your Personal Information, to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms of Service or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the Website or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion.
4. Analytics and Similar Third Party Services and Your Choices
We may partner with third party advertising companies to either display advertising on the Website or to manage our advertising on other sites, and we may use third party analytics service providers to evaluate and provide us with information about the use of the Website and viewing of our content. Ad network providers, advertisers, sponsors, analytics service providers and/or similar third parties may set and access their own cookies, local storage, web beacons and embedded scripts on your device, may collect, set and use unique or non-unique identifiers, and they may otherwise collect or have access to information about you.
We and our network advertisers may target advertisements and offers to you, both on our websites and elsewhere online, based on your visits to our Website and online services and those of third parties. Cookies, web beacons, and other technologies, including those set by third party network advertisers, may be used to, among other things, target advertisements, limit the number of times you see the same advertisements, conduct research regarding the usefulness of certain advertisements to you, track how our users interact with our websites, link various devices you may use, and learn more about users.
We may use a variety of companies to perform advertising and analytics on the Website including:
We also use Google Analytics Advertising Features in order to obtain demographic and interest reports. We utilize first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together to analyze your other information and your interest. If you choose to opt out Google Analytics Advertising Features, please disable Cookies by setting your browser or use Google Analytics Opt-out Browser Add-on.
Some of our service providers may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may wish to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an opt-out for participating companies.
"Do Not Track" Signals- Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Website does not currently interpret, respond to or alter their practices when they receive Do Not Track signals. Please note that third parties may collect personal information about your online activities over time and across different websites when you visit our Website or other online websites. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
5. Links To and Sony Content On Other Websites
The Website may contain links to other websites that are operated and controlled by third parties that we do not control. In addition, the Website or other Sony content may be included on web pages and other online services that are not associated with us and over which we have no control and which may send their own cookies to your Device and independently collect data or solicit Personal Information. A link from our Website to any other online content does not mean that Sony approves of, endorses, or recommends it. Sony is not responsible for the privacy practices of any third party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content it does not own and control.
6. Notice to California Residents
CA Privacy Notice – Effective January __, 2020 [Insert date posted]
If you reside in California, we are required to provide additional information to you about how we collect, 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.
o Personal Identifiers: name, email address, mailing address or phone number;
o Other Identifiers: such as IP address, Device ID or other unique identifiers;
o Commercial Information: such as product types or applications purchased or obtained, transaction information or similar information;
o Internet or Other Electronic Network Activity: such as computer or connected device information, operating system, screen views, traffic to and from applications, other web traffic or connectivity information; and
o Geolocation Data: such as physical location information through the use of our Website on your phone or computer;
o Other Consumer Characteristics: such as demographic information, user profile or inferences drawn based on your browsing or purchase history.
CA Personal Information Sold or Disclosed For Business Purposes.
• “Sale” of CA Personal Information: In the preceding twelve months, we have not “sold” (as defined under the California Consumer Privacy Act) CA Personal Information.
“Do Not Sell My Personal Information.” If we sell your CA Personal Information to a third party, you have the right to opt-out of the sale of your CA Personal Information. If you wish to exercise this right, you may submit a request here: Do Not Sell My Info , or by calling the following toll-free number 1-833-681-9900, or sending an email to email@example.com. If you are under the age of 16, we will not sell your CA Personal Information without affirmative authorization.
Exercising Your Rights. If you are a California resident and wish to exercise any of these rights, please: (a) access the appropriate webform link above; (b) contact us by sending an email to firstname.lastname@example.org with the specific nature of your request, referencing “Your California Privacy Rights”; or (c) 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, or in connection with any promotion or other offering, 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. We may require additional proof of authority or may need to contact you directly to validate the request.
Additional Notice to California Residents
If you are a California resident, you have the right to receive: a) information identifying any third party company(ies) to whom Sony 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 Privacy@am.sony.com. Requests must include your name, email address 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.
Sony uses commercially reasonable safeguards to help protect and secure your Personal Information, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of Personal Information we share with them. However, no electronic or wireless data transmission or electronic storage of information can be guaranteed to be 100% secure. Sony does not ensure or warrant the security of any information we collect, and you use the Website and provide us with your information at your own risk.
8. Consent to Processing
The Website is operated in the United States. If you are located in the European Union, Canada or elsewhere outside of Japan, please be aware that information we collect will be transferred to and processed in United States. By using the Website, or providing us with any information, you fully understand and unambiguously agree that such information may be processed in a country other than your home country, and you consent to this transfer, processing and storage of your information in another country, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Sony Electronics Inc.
115 West Century Rd., Suite 250
Paramus, NJ 07652
Attn: Privacy Office