PRIVACY POLICY FOR “SONY | BRAVIA CONNECT” APPLICATION AND SOUND BAR AND HOME THEATER PRODUCTS

Effective Date: This Privacy Policy was revised and is effective as of April 23, 2024.


This Privacy Policy applies to the “Sony | BRAVIA Connect” (“Application”) and SONY’s certain sound bar and home theatre products connected to your Application. Such SONY’s sound bar and home theatre products are those that are compatible for connection with the network (“Sound Bar and Home Theatre Products”). This Privacy Policy explains how we use what types of your personal data, with whom we share the data, how we transfer it to other countries/regions, how long we keep the data, what rights and choices you have and how you can contact us with queries when you use the Application and/or the Sound Bar and Home Theatre Products.

The Application is a mobile application dedicated to audio/visual devices from SONY. The Sound Bar and Home Theatre Products are SONY’s sound bar and home theatre products that are connected with the Application for the Application to control such devices and can connect with the network.

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. 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 obtain?

SONY collects and uses information or data as described below. Some of this information and data may be considered personal information under applicable law in your jurisdiction. These are collected when you choose to provide information to us or automatically when you use (1) the Application and (2) the Sound Bar and Home Theatre Products (collectively, the “Collected Data”).

(1) Information collected via the Application

(i) Information collected via SHES Account

(a) Before sign-in authentication

To link the Application with the Sound Bar and Home Theatre Products, you will be required to create a Sony’s cloud service account for Home Entertainment & Sound Products (“SHES Account”) according to the Terms of Use andPrivacy Polic y.

In order to create an SHES Account, you will first need to provide sign in authentication via either (1) a Sony account (SHES Cloud service) or (2) an authenticatin by Google, Inc. (“Google”), Meta Platforms, Inc., Amazon.com, Inc. (“Amazon”) or Apple, Inc. (“Apple”) (collectively referred to as “ID provider”) authentication.

More information about the data we collect in connection with each authentication method is below. We use cookies, activation codes and/or tokens as necessary for us to provide you SHES Account service or to link your device to a service.

If you choose to create or use a Sony account (SHES Cloud service) for authentication when you create a SHES Account, SONY will collect the following:

We also collect information about your usage of the website of the SHES Account (access status, etc).

Once you have successfully signed into your Sony account (SHES Cloud service), your mobile device will receive a digital ‘access token’ from this Sony account (SHES Cloud service). Please be aware that some Sony accounts for other Sony group services will be linked automatically if you use the same sign-in ID and password. For more information about linking accounts, please go to: https://acm.account.sony.com/linking-account

For password management and authentication, you can also register a security question and answer and telephone number at the Sony account (SHES Cloud service) security setting page. This Collected Data is not used for any other purpose.

If you choose to use an ID provider authentication when you create a SHES Account, SONY will collect the following:

Please note that the information we collect from and through an ID provider may depend on the privacy settings you have set with the ID provider and the permissions you grant to us in connection with linking your SHES Account to your account with an ID provider. We do not share any Collected Data with the ID provider, and the personal information an ID provider has about you is obtained by the ID provider independent of our service and Sony is not responsible for it.

For more information how relevant ID provider handles the processing of your data, please visit the following websites:

(b) After sign-in authentication

After you have completed sign-in authentication, you will create your SHES Account and we will assign identifiers, issue tokens and collect the following information you provide:

Please note that such identifiers and tokens may be linked with the Collected Data.

Please note that you may create separate SHES Accounts for each email address you choose to use.

If you would like to know more about the processing of information above, please refer to the SHES Account Privacy Policy>.

(ⅱ) Information about your device on which the Application is installed (the “Installed Device”) and component parts thereof:

(ⅲ) Information about the Application:

(ⅳ) Information about your SONY product(s) which are detected by or registered to the Application (“Related Device”):

(Ⅴ) Information collected by surveys:

From time to time, SONY may ask you whether you would like to participate in one of our surveys. We may ask for information, such as your interests and preferences with regard to current and future products and services on the market.

You can decide not to participate in the survey by closing the browser or tabs of the survey at any point during the survey.

(2) Information collected via the Sound Bar and Home Theatre Products

(i) Information about your Sound Bar and Home Theatre Products

3. How does SONY use the Collected Data?

SONY processes your Collected Data for the purposes listed hereafter:

(i) Providing the minimum functions of the Application and Sound Bar and Home Theatre Products

SONY processes the Collected Data to provide or operate the features and functions of the Application and Sound Bar and Home Theatre Products.

Please note that the legal basis under EU-law for SONY processing Collected Date for providing the minimum functions of the Application and Sound Bar and Home Theatre Products is the necessity of performance of the EULA we have with you.

(ⅱ) Pushing updates to the Application or your Related Device

Each time you start the Application on your Installed Device, the Application sends a “request” to SONY's server to check whether any updates for the Application or the firmware of the Related Device (including Sound Bar and Home Theatre Products) are available and to send latest software or firmware in case any update should be available. For this, we only use your IP address.

Please note that the legal basis under EU-law for SONY processing your IP address data for pushing updates to the Application or Related Device is the necessity of performance of the EULA we have with you.

(ⅲ) Providing “Help” upon your request

If Help is requested by you, certain technical information about the Installed Device, about the Application and about the Related Device are transferred to SONY in order to provide service to you through the Help feature. This transfer of data enables SONY to provide you with “customized” Help webpages for the Application and Sound Bar and Home Theatre Products and the specific technical issue you experience. For this, we process the following Collected Data:

Please note that the legal basis under the EU-law for SONY processing Collected Data for providing “Help” upon your request is that such processing is for services and support necessity for the purposes of our legitimate interests pursued by Sony. The legitimate interest pursued by SONY in relation to our use of your Collected Data is the efficient and effective provision of support to our customers.

(ⅳ) Improving/developing SONY´s products and services

SONY uses the Collected Data (except data collected solely for backup and restoration service) listed in Section 2 above (except for Section 2 (1)(i)) to improve and develop SONY’s current and future products and services where you tap “AGREE AND PROCEED” on “Data use for product/service improvement purposes by Sony Corporation in Japan (“Sony”)” screen. Such Collected Data may be linked and analyzed in conjunction with the data we collect through other Sony products and audio applications if you use one of those. For the colected data through those products or applications, please refer to the privacy policies for those products or applications. Product improvement and/or development includes those relating to either an improvement of the technical functions of the Related Device or the usability of SONY’s products and services. Such product improvement/development is only done on a “general” level, not on an individual user level, so specific users are not targeted. This includes through analyzing log-files of the app usage.

SONY may for this purpose ask you whether you would like to participate in one of our surveys. You can decide not to participate in the survey by closing the browser or tabs of the survey at any point during the survey.

Please note that your consent forms the legal basis for SONY processing Collected Data for improving/developing SONY’s products and services under EU-law.

In this case, we process the Collected Data listed in Sections 2 above because you have given us your consent.

You can withdraw your consent above for Collected Data via the Application at any time by selecting "(3 dots) Menu" > "About this app" > "Privacy settings" in the Application.

(ⅴ) Sharing the Collected Data with Sony Europe B.V. to provide you with information and advertisements

You can withdraw your consent above for Collected Data via the Sound Bar and Home Theatre Products at any time by selecting "Devices and Information" and going to "Settings" > "Network Settings" > "Privacy Settings" in the Application.

General Marketing via display ads

SONY shares the Collected Data with Sony Europe B.V. for the following purposes.

Tailored Marketing and messages

If you tap “AGREE AND PROCEED” on “Data use for marketing by Sony Corporation in Japan (“Sony”) or Sony Europe B.V. (“SEU”)” screen, for Collected Data collected via the Application SONY will collect and share with Sony Europe B.V. your as described in Section 2, (1)(ii), (iii) and (iv) and Section 2(2) above (including your digital identifiers) to provide you with general information, recommendations advertisements, and marketing regarding Sony products, services and other offerings that may be of interest to you. Such advertising may be delivered to you across Sony and third party websites and social networks that you visit and Sony and thirds party apps which you use.

If you tap “AGREE AND START USING” on “Data use for marketing by Sony Corporation in Japan (“Sony”) or Sony Europe B. V. (“SEU”)” screen for Collected Data collected via the Application and/or Sound Bar and Home Theatre Products, SONY will collect and then share with Sony Europe B.V. (EU) your personal data as described in Section 2 (1)(i), (ii) (iii) and (iv) and/or Section 2(2) above (including your digital identifiers), as appropriate. Subsequently, Sony Europe B.V. will personalize or tailor the messages sent to you so that you can receive new product information, articles, offers and promotions, or support information that are tailored to your interests and needs. You may notice this personalization and targeting when you use Sony products and services, when Sony Europe B.V. contacts you with marketing communications and when you visit Sony and third party websites or apps, social networks and services that show advertisements from SONY or our advertising partners (for example, you might see an advertisement relevant to a product that you have recently used).

SONY or Sony Europe B.V. will for this purpose evaluate your preferences and interests based on your personal data above through profiling.

Please note that your consent forms the legal basis for SONY to collect and share Collected Data with Sony Europe B.V. to provide you with information and advertisements under EU-law.

You can withdraw your consent above at any time by selecting "(3 dots) Menu" > "About this app" > "Privacy settings" in the Application.

4. Who else has access to the Collected Data?

We do not share Collected Data with third parties for their own marketing purposes. The Collected Data that is communicated to and stored by SONY may be made available to SONY Affiliates and to other third parties, as follows:

Sony Europe B.V.

The Collected Data may be shared with and used by Sony Europe B.V. as an independent controller for the purposes of “Sharing the Collected Data with Sony Europe B.V. to provide you with information and advertisements” (Section 3 (v)). If you contact Sony Europe B.V. in relation to queries on the Applications, or for repair or return requests of Related Devices, we may also need to share Collected Data with Sony Europe B.V. in connection with that your requests.

Service Providers

SONY and Sony Europe B.V. may use Sony Global Solutions in Japan and other third party contractors as processors/service providers to process the Collected Data on their behalf for the purposes set out in this Privacy Policy. Such third party contractors are IT service providers or data hosting providers. Our hosting provider is Amazon Web Services in the US, acting as our processor.

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 Sony Affiliate to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer.

Government Authorities/ Law Enforcement Officials

Collected Data may be disclosed to government authorities and/or law enforcement officials if required laws or if necessary for us to protect our legitimate interests, or the interests of others, in compliance with applicable laws.

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 to help us fulfil our legal obligations.

Firebase and Apple Push Notifications service

The Application uses Firebase, a service provided by Google Inc.(“Google”) for Android user, and Apple Push Notifications service, a service provided by Apple Inc.(“Apple”) for iOS user, in order to provide you push notice function. To better understand how Google and Apple use the information it receives, visit:

Google, https://policies.google.com/privacy

Apple, https://www.apple.com/legal/privacy/en-ww/

5. 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.

With regard to Collected Data which is processed based on your consent declaration, SONY will apply a maximum of twenty-seven (27) months retention period from the date of the collection of the Collected Data.

Collected Data which is processed for pushing updates to the Application or Related Device will be deleted after the Internet communication required for this is completed.

Collected Data which is processed for providing Help to you upon your request will be deleted after the requested Help has been provided to you.

6. Transfer of the Collected Data internationally

The Collected Data will be processed, stored and transferred for the purposes outlined in Section 3 to countries/regions outside the European Economic Area (EEA) and/or your country/region of residence, including in particular Japan and the United States.

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.

As the Collected Data will be transferred to and processed in countries outside the EEA and the UK, where the privacy laws may not provide an equivalent level of protection to those in your home country, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the European Commission or the UK Government, the Collected Data is adequately protected by Standard Contractual Clauses approved by the European Commission which can be accessed here, the addendum to the EU Commission’s standard contractual clauses or standalone international data transfer agreement approved under the UK data protection law (as applicable) or a stakeholder’s/vendor’s Processor Binding Corporate Rules. If you have questions or concerns about SONY's data transfer arrangements, or if you require a copy of the relevant mechanism, please contact us as described in Section 11. Contact Information below.

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 Application and/or Sound Bar and Home Theatre Products, or that SONY stores on its systems or that is stored on SONY’s third party contractors' systems.

8. Policy Regarding Children

SONY 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/regions. This Application and Sound Bar and Home Theatre Products is intended for a general audience; these are not directed to and does not knowingly collect personal information from children younger than age 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 SONY with personal information (as defined by applicable law), you should contact us as indicated below.

9. Privacy Rights

In some countries/regions, you have certain rights with respect to the Collected Data SONY or Sony Europe B.V. holds about you. These may include the right as indicated below. 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.

You may have the right to:

You can exercise these rights by using the 11. Contact Information details below.

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.

Please note that automated decision-making including profiling, which produces legal or other similar material effects currently does not take place on our Application(s) and/or Sound Bar and Home Theatre Products with regard to Collected Data for the purposes set in this privacy policy.

If you have unresolved concerns, you have the right to complain to a data protection authority in the country where you live, work, or where you believe a breach has occurred. Details of EU data protection authorities is available here and the website of the data protection authority of the UK Information Commissioner’s office is here .

10. Changes

SONY will notify you of any changes to SONY’s Privacy Policy by posting the new Privacy Policy here and by prominently posting notice of the amendment on the Application. You are advised to consult the posted Privacy Policy regularly for any changes.

11. Contact Information

This Privacy Policy applies to: SONY as a data controller. SONY's address is 1-7-1 Konan Minato-ku, Tokyo, 108-0075 Japan.

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have in respect of the Collected Data, please contact us at www.sony.net/SonyInfo/Support/

If you are in the EU or Switzerland:

Sony Corporation, a Japanese company, is the controller for the Collected Data. Our representative in the EU is Sony Europe B.V., a Dutch company, whose business address is Taurusavenue 16, 2132LS Hoofddorp, the Netherlands. If you have any concerns about how we process your data, you can contact our representative in the EU by emailing:privacyoffice.SEU@sony.com. You can also get in touch by writing to Sony Europe B.V. at the address above or at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.

If you are in the United Kingdom:

Sony Corporation, a Japanese company, is the controller for the Collected Data. Our representative in the UK is Sony Europe B.V., a Dutch company, whose UK branch has its business address in The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom. If you have any concerns about how we process your data, you can contact our representative in the UK by emailing:privacyoffice.SEU@sony.com. You can also get in touch by writing to The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.