Privacy Policy for “Monitor & Control”
Last Updated: 2024-05
This Privacy Policy sets out how Sony Electronics Inc. (“Sony”, “we”, “our” or “us”) collects, uses, stores and otherwise processes the Collected Data (defined below) in relation to Sony’s “Monitor & Control” mobile application (“M&C”). It also describes your data protection rights, including the right to object to some of the processing which Sony may carry out. More information about your rights, and how to exercise them, is set out in Section 8 “Privacy Rights” below.
We also may provide you with additional information when we collect Collected Data, where we feel it would be helpful to provide relevant and timely information.
For the purposes of applicable data protection laws and regulations where the concepts of "controller" and “processor” are defined, Sony is the "controller" of the Collected Data described in this Privacy Policy.
“Sony Group Companies” 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).
This Privacy Policy only applies to M&C and is in addition to any other privacy policy or privacy notice that may apply to your interactions with any Sony Group Company or any third party regarding their products, software or services.
Table of Contents
1. What personal information we collect
2. Why we process personal information
3. How we share your personal information
4. How long we retain your personal information
5. International transfers of personal information
9. Changes to this Privacy Policy
Sony collects data inclusive of, but not limited to, data as described below which may include personal information (collectively, the “Collected Data”) related to your use of M&C:
l Information to identify you and other personal identifiers
This includes information such as:
- If you have a Sony Account (Creators’ Cloud), your log-in information. For more information about Sony Account (Creators’ Cloud), please go; Terms/Privacy (sony.com); and
- Your universally unique identifier (UUID) for M&C and your account ID for Sony Account (Creators’ Cloud); and
l Information we collect automatically about your use of M&C
This includes information such as:
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- The operation log of each function and usage information such as settings, shooting equipment and utilization volume.
l Information we collect automatically about devices used to access M&C and your settings
This includes information such as:
- Your IP address, software version, installation date and operation logs;
- Mobile device model name, manufacturer’s name, OS version, language and device ID (in relation to M&C); and
- Country/region settings, language.
l Information about the camera devices you use with M&C
This includes information such as:
- Serial number, model name, settings, errors/cautions; and
- Operating log including shooting date/times, mount lens and mount media.
Sony processes your Collected Data for the purposes listed hereafter:
l Provision of products and services
Sony processes Collected Data in order to provide M&C and other services linked to M&C where applicable. This includes:
- Managing the customer relationship;
- Responding to inquiries and providing customer support; and
- Sending necessary communications.
l Protecting the interests of Sony Group Companies and M&C users
Sony processes information in order to protect the Sony Group Companies, their business interests and legal rights and M&C 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 process or litigation). Sony may process information to identify such a user of M&C who has breached, or is reasonably suspected to have breached, our terms, policies, including any other terms of service the user has agreed to, and any rules or codes of conduct applicable to the user’s use of M&C.
l Managing security or technical issues
Sony processes information in order to detect, prevent, address and analyse security or technical issues in relation to our website, app and services.
l Compliance with law
Sony processes Collected Data in order to comply with applicable law and regulation, this includes responding to requests from government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws.
l Product / service development and improvement and analytics
If you give us consent, Sony collects and shares information with Sony Group Companies in order to improve Sony’s products and services, to develop new ones, to predict the demand for those products and services so that we can provide improved user experiences for current and/or future products and services and to help us develop our advertising and marketing strategies.
You can manage your preferences (including withdrawing consent) s at any time through the Privacy Settings in the Menu function.
We share Collected Data with third parties as follows:
l Sony Group Companies
We share Collected Data with Sony Group Companies to the extent such sharing of data is necessary for the purpose set forth above and to fulfil a request you have submitted and/or for customer support, technical operations, or account management purposes.
l Service providers and contractors
We share Collected Data with service providers and contractors who provide services such as IT and system administration and hosting, research and analytics, and customer support for the purposes described in Section 2 above.
l Business transfer
Sony or any of its assets, including M&C, may be sold, or other transactions may occur in which your personal information is one of the key business assets for 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 a corporate merger, consolidation, restructuring, reorganization, the sale of certain stock and/or assets, or other corporate change including, without limitation, during the course of any due diligence process.
l Government authorities, law enforcement officials, regulators courts and similar
We share Collected Data with government authorities, law enforcement officials, regulators, courts and similar for the purposes described above in Section 2.
l Professional advisers
In individual instances, we may share Collected Data with professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
We retain all categories of Personal Information described in this Privacy Policy for as long as it is reasonably necessary for the purposes outlined in this Privacy Policy, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently on specific pages or in apps, we retain your Personal Information while you have an account with us, or while you are using M&C or continuing to interact with us.
When we no longer need to use your information, we will take steps to remove it from our active systems and records and/or to properly anonymize it so that you can no longer be identified from it. Even if we delete your information from active databases, the information may remain on backup or storage media to the extent allowed by applicable law.
Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy from your country/regions of residence to countries/regions outside your country/region of residence, including Japan and the US. 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, including in the locations set out in Section 3 “How we share your personal information” above. Some of the countries and regions may not provide the same level of data protection as your country. By using M&C, or providing us with Collected Data, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions. As a result, courts, law enforcement, and other authorities in countries/regions outside your residence may be entitled to access Collected Data upon its transfer.
Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive to protect Collected Data, we cannot guarantee or warrant the security of any information transmitted to us through your M&C or that we store on our systems or that is stored on our third-party contractors’ systems and any information you provide is done at your own risk.
M&C is not directed to and does not knowingly collect personal information from children under the age of 16. 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 personal information without your consent, you should contact us as indicated in Section 10 “Contact Information” below.
In some countries or jurisdictions, you may have certain rights with respect to the Collected Data Sony processes about you. These may include the right to request a copy of the Collected Data that Sony holds about you and/or you may request that Sony, correct, delete, block/restrict processing of such Collected Data. In some countries or jurisdictions, you may also ask us to provide your Collected Data to you in a structured, machine-readable format and ask us to share (port) such data with another organisation. These rights may be limited, for example, if fulfilling your request would reveal Collected 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 of these rights, please refer to the section regarding “Jurisdiction Specific Rights” or contact us as described in Section 10 “Contact Information” below.
This Privacy Policy may be updated from time to time for any reason. We will notify you or request your consent (if necessary under applicable law) of any changes to this Privacy Policy.
If you have any questions or comments about our practices regarding collected data or about this Privacy Policy, please contact us at:
l United States:
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
l Canada:
Sony of Canada Ltd.
2235 Sheppard Avenue East, Suite 800
Toronto, ON M2J 5B5
Attn: Privacy Officer, Law Department
Telephone, toll-free (within Canada): 1-888-494-7669
Email: privacy@am.sony.com
Notice to US Residents (excluding CA):
We set forth above in our Privacy Policy and in [Table 1] below 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.
If you reside in a state with a comprehensive privacy law, you may have the following rights with respect to their personal data subject to the meanings and exceptions set forth in applicable state law:
1. To confirm whether we are processing your Personal Data and request to access such data.
2. That we correct inaccurate Personal Data we hold about you.
3. That we delete the Personal Data provided by you or obtained about you.
4. To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.
If you are an eligible consumer and would like to exercise any of these rights, please complete the form here: Data Requests.
Opt-out of Targeted Advertising: You may also have the right to opt-out of the processing of Personal Data for the purposes of targeted advertising. Sony engages in online advertising and analytics practices that may be considered “targeted advertising” under applicable law. To exercise your rights to opt-out of targeted advertising, you may submit a request here: Opt-out of Targeted Advertising.
In addition, you may need to disable sharing through cookies set by 3rd parties on certain Sony websites which may be considered targeted advertising. To manage your cookie preferences, please refer to the “Manage Cookies” or “Cookie Policy” link on the cookie banner or in the footer for the applicable website and ensure that “Targeting Cookies” are disabled.
While applicable law may also permit you to opt-out of the sale of your Personal Data, at this time we do not engage in the “sale” of Personal Data to third parties for monetary compensation. However, Sony may sell your Personal Data for other valuable consideration, which you may opt-out of by submitting a request here: Opt-out of Targeted Advertising. Additionally, we do not process your Personal Data for purposes of profiling as set forth in applicable law that would require such an opt-out.
Appeals
Pursuant to applicable law, if, for any reason, you would like to submit an appeal to us relating to your request, you can do so by completing this form: Data Requests. Please include your full name, the basis for your appeal, and any additional information to consider.
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 in case that Sony were to engage in such a sale in the future, you may submit your request in writing to: privacy@am.sony.com. Your request must reference your Nevada rights and include your name, mailing address, zip code, and email address. Your request is subject to verification of your identity by us and validation of your request. 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. Sony will respond to valid requests within sixty (60) days.
Notice to California Residents:
This California Privacy Notice is effective as of May 1, 2024.
This California Privacy Notice supplements our Privacy Policy and applies only to California residents. This notice sets forth the disclosures and rights for California Consumers regarding their personal information, as required 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 CA Personal Information:
· Right to Know. Request information regarding what Personal Information we collect, use, disclose, and sell, including the right to request that we provide you with the categories and/or specific pieces of Personal Information we have collected about you;
· Right to Delete. Request deletion of the Personal Information we collect about you;
· Right to Correct. Request correction of inaccurate Personal Information that we maintain about you;
· “Do Not Sell or Share My Personal Information.” Request to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising). As we do not knowingly collect Personal Information of residents younger than the age of 16, we also do not knowingly sell or share for cross-contextual behavioral advertising their Personal Information.
“Limit the Use and Disclosure of Sensitive Personal Information.” Under the CPRA, we must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or it does not fall under certain statutory exceptions. Sony’s use and disclosure of Sensitive Personal Information is not used for such purposes and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
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 can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. 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 that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sale or Sharing.
Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable fields of information in the submission form. 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 Probate Code sections 4000-4465. 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. 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.
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.
For requests to know, in order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Do Not Sell or Share for Cross Context Behavioral Advertising
Right to Opt-Out of Sale/Sharing
California Consumers have the right to opt-out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). California Consumers also have the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration. Please note that we do not sell Personal Information for monetary consideration. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale or Sharing, please submit your request at: Do Not Sell or Share My Personal Information.
Cookie Based Opt-Outs for Do Not Sell or Share for Cross Context Behavioral Advertising
Sony engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CPRA. In addition to submitting the form above, you may need to disable sharing through cookies set by 3rd parties on certain Sony websites. To manage your cookie preferences, please refer to the “Manage Cookies” or “Cookie Policy” link in the cookie banner or footer for the applicable website and ensure that “Targeting Cookies” are disabled.
We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using M&C or continuing to interact with us.
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.
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 M&C or otherwise interact with us. 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 the CPRA.
We may have used Personal Information for the following business or commercial purposes:
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Categories of Personal Information Collected |
Business or Commercial Purposes for Collection of Personal Information |
Categories of Sources from Which Personal Information Was Collected |
Categories of Third Parties to Whom We May Disclose Personal Information for a Business Purpose |
Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared for Cross Context Behavioral Advertising |
|
Identifiers This category includes information such as name, phone number, mailing address, email, DOB, and online or device identifiers such as Device IDs and IP address. |
We may use this type of information to: Create and manage your account(s); provide requested services; process transactions; respond to your inquiries; send you information on products, services, promotions and other offerings; personalize your experience on our websites, apps and online; provide you updates on your account, your products and our websites, products and services; maintain and improve our products and services; monitor and maintain security of our systems and prevent fraud; internal business, legal and compliance purposes |
We may collect this type of information from: Consumers; Sony Group companies; Third-Party Business Partners; Cookies; Consumer Data Providers (such as market research firms/data aggregators) |
We may disclose this type of information to: Sony Group companies; IT Service Providers; Data Analytics and Advertising Providers; Business Partners; Legal Authorities (as required by law); Business Transfer Recipients. |
Third party advertising, analytics, and other similar marketing business partners. |
|
Commercial Information This category includes, for example, products or services purchased, obtained or considered, other purchasing or consuming histories, credit card or payment information, or transaction history. |
Create and manage your account(s); provide requested services; process transactions; respond to your inquiries; provide information and updates on your products, services or features; internal business, legal and compliance purposes; prevention of fraud |
Consumers; Sony Group companies; Business Partners |
Sony Group companies; IT Service Providers; Data Analytics and Advertising Providers; Business Partners; Legal Authorities (as required by law); Business Transfer Recipients. |
None. |
|
Internet or Other Electronic Network Activity This category includes information such as computer and connection information, browser type, operating system, page views, traffic to and from the websites, advertising data and other standard weblog information collected via cookies and web beacons. |
To personalize your experience on our websites, apps and online; develop and deliver marketing communications; maintain and improve our products, services and features; serve advertising; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes |
Consumers; Sony Group companies; Third Party Applications; Advertising Networks |
Sony Group companies; IT Service Providers; Data Analytics and Advertising Providers; Advertising Networks; Legal Authorities (as required by law); Business Transfer Recipients. |
Third party advertising, analytics, and other similar marketing business partners. |
|
Audio, Visual and Similar Electronic Information This category includes, for example, pictures or videos you submit to us or M&C. |
Provide features and services, including customer service; manage participation and use of forums |
Consumers; Sony Group companies |
Sony Group companies; IT Service Providers; Data Analytics Providers; Legal Authorities (as required by law); Business Transfer Recipients. |
None.
|
|
Sensitive Information Such as account log-in credentials and geolocation. |
Authentication of your account or identity and providing services, features or functions |
Consumers |
None |
None |
|
Inferences Drawn from Other Information and Consumer Characteristics These may relate to demographics (e.g., gender, age, region/general location, language, profession or job title), interests or hobbies, and inferences drawn from collected information, purchase or browsing history. |
To develop and deliver marketing communications; to personalize your experience on our websites, apps and online; develop, maintain and improve the products, services and features offered by us and the Sony Group companies |
Consumers; Sony Group companies; Third-Party Business Partners; Third Party Applications; Consumer Data Providers |
Sony Group companies; IT Service Providers; Data Analytics Providers; Advertising Networks; Legal Authorities (as required by law); Business Transfer Recipients. |
Third party advertising, analytics, and other similar marketing business partners. |
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 companies 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 privacy@am.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.
Notice to Canadian Residents:
Subject to applicable law, if you are a Canadian resident and would like to submit a request to access, correct, or update your personal information, you may submit your request by visiting this link: Sony Canada Data Request; or you may call us at: 1-888-494-7669. You may also use this contact to submit any requests for information on our privacy practices or to submit a complaint regarding our practices.
For requests to access your personal information, we may require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information for Residents in Québec
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.
Profiling: We may use certain technologies that allow you to be identified or profiled in order to improve your experience on M&C, to personalize our marketing or perform targeted advertising. You may change your privacy settings as described in the privacy policy at any time.
Location Tracking. We may use technologies that allow us to identify your general location, such as your country. However, we will not track your location without your consent.
Consumer Rights: We will only use your personal information for the purposes stated at the point of collection or as otherwise noted in this privacy policy. Subject to certain exceptions, you may have the following rights regarding your personal information:
• Right to Inform/Access. Request information about our data processing activities, namely what personal information was collected from you and how we process it.
• Right to Correct. Request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Automated Decision-making. You have the right to request that we tell you if we use your personal information to render a decision based exclusively on automated processing of such information and additional information about such processing. However, we do not use personal information to render any decisions based exclusively on an automated processing of such information.
• Right to Withdraw/Restrict Processing. Withdraw your consent to our collection, use, and disclosure of personal information at any time.
If you would like to submit a request to exercise your rights, you may submit your request here: Sony Canada Data Request.
Our Privacy Officer is in charge of the protection of personal information. You may contact the Privacy Officer by emailing privacy@am.sony.com or calling toll-free (within Canada): 1-888-494-7669. You may also 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/.