Privacy Policy for “Monitor & Control”
Last Updated: 2024-05
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 the Collected Data (defined below) in relation to our “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 carries 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 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 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.
We have provided some additional information for individuals located in the European Economic Area (“EEA”) and the UK (together, “EEA/UK Individuals”).
1. What personal information we collect
Sony collects 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 to Terms/Privacy (sony.com); and
- Your universally unique identifier (UUID) for M&C and your account ID for Sony Account (Creators’ Cloud).
l Information related to contact and support interactions with us
This includes any contact with our customer services team, and we may collect additional information from you via calls, chat, text or other means, some of which may be recorded.
l Information we collect automatically about your use of M&C
This includes information such as:
- 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; 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 logs including shooting date/times, mount lens and mount media.
2. Why we process personal information
Sony processes your Collected Data for the purposes listed hereafter:
l Provision of products and services under the contract you have with us
Sony processes Collected Data in order to perform its contract with you 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;
For EEA/UK Individuals: The legal basis for the processing above is the performance of the contract that we have with you.
l Our legitimate business interests as set out below
- 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).
- 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.
- Undertaking mergers, acquisitions, reorganizations or disposals
For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for Sony’s legitimate interests as described above.
l Compliance with law
Sony processes Collected Data in order to comply with applicable law and regulations, 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.
For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for compliance with a legal obligation, including obligations under the E-Commerce Directive (as implemented into member state & UK domestic law), the Digital Services Act, the Directive on Copyright in the Digital Single Market and the Geo-blocking Regulation. With regard to special category data processed for content moderation purposes the legal basis is compliance with a legal obligation. In relation to the relevant condition to process special category data in the context of content moderation this is public interest associated with the provision of M&C on the basis of the EU laws mentioned above and in the UK also for the prevention and detection of crime or the need to safeguard children and vulnerable individuals.
l Product / service development and improvement and analytics
If you give us consent, Sony collects and analyses Collected Data in order to improve Sony Group Companies’ 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. We may also use Collected Data to help us determine what kinds of products and services you might be interested in.
You can manage your preferences (including withdrawing consent) at any time through the Privacy Settings in the Menu function.
For EEA/UK Individuals: The legal basis for the above is your consent where we have obtained your consent for such activities. Where the activities are not consent-based, the legal basis is our legitimate interests in marketing and promoting our business.
3. How we share your personal information
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 to fulfil a request you have submitted and/or for customer support, technical operations, or account management purposes.
l Third-party contractors
We share Collected Data with third-party 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
In the event that we undertake a merger, acquisition, reorganization or disposal, Collected Data may be transferred to the purchasing or acquiring entity as part of the transaction.
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.
4. How long we retain your personal information
We retain Collected Data for as long as we continue to make M&C available to customers, and for a further 6 months following discontinuation, at which point the information will either be anonymized or destroyed. Please note that we may be required to retain certain information by law.
5. International transfers of personal information
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.
For EEA/UK Individuals: Sony takes appropriate measures to ensure that all transfers of Collected Data to 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, and where this is to a stakeholder or vendor in a country 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. Security
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.
7. Children
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children. 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.
8. Privacy rights
In some countries, you 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 corrects, deletes, blocks/restricts processing of such Collected Data. You may also object to Sony’s processing of Collected Data. In some countries, 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 contact us as described in Section 10 “Contact Information” below.
If you are not satisfied with how we have handled your questions, concerns or have any complaints about how we process Collected Data, you have a right to lodge a complaint with a data protection supervisory authority.
Where we collect Collected Data to administer our contract with, this is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of the requested Collected Data is optional, but this may affect your ability to use the services or use particular aspects of the services where the information is needed for those purposes.
For EEA/UK Individuals:
You have the right to:
- Ask Sony for a copy of your personal data
- Correct, delete or restrict processing of your Collected Data
- Obtain the Collected Data you provide in a structured, machine-readable format
- Object to the processing of your Collected Data in some circumstances (in particular, processing for the purposes of direct marketing and where we do not have to process the data to meet a contractual or other legal requirement) and
- Where we have asked for your consent, withdraw consent at any time. If you ask to withdraw your consent to Sony processing your information, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal information 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.
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
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/.
For EEA/UK Individuals:
Sony’s representative in the EU is Sony Europe BV that can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to to its business address at Taurusavenue 16, 2132LS Hoofddorp, the Netherlands.
Sony’s representative in the UK is the UK branch of Sony Europe BV who can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe BV (UK branch), The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.