Last Updated and Effective Date: 5/1/2022
This privacy policy (“Privacy Policy”) applies to the “Sony’s TV” Skill Application (“Application”). This Application enables your Amazon Alexa-compatible device to control your BRAVIA TV. This Application will enable you to link your Amazon Alexa-compatible device with the “TV Control with Smart Speakers” application on your BRAVIA TV.
In this Privacy Policy, when we say “Sony”, “we”, “us” and “our”, we mean Sony Corporation, with an address of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan. Sony acts as data controller (as this term is defined under the General Data Protection Regulation ((EU) 2016/679) or any other applicable local legislation or regulation) and may collect and consolidate certain information about you, this Application and/or your TV. This is explained in detail in this Privacy Policy.
In this Privacy Policy, “Sony group company” shall mean the parent company of Sony and any legal entities controlled by such parent company (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 the Application and is in addition to any other privacy policy that may apply to your interactions with any Sony group company or any third party, regarding their product, software or service.
PLEASE NOTE: In order to use this Application, you will need to set up a Sony's Cloud Service for Home Entertainment & Sound Products Account, which has a separate privacy policy.
1. SUMMARY OF KEY POINTS
· Sony uses the “Collected Data” (defined below) to provide you with features and functions of the Application. Please read Section 2 (What Collected Data does Sony receive about you?) and Section 3(How does Sony use the Collected Data?) to learn more.
· This Privacy
Policy describes your data protection rights, including a right to object to
some of the processing which Sony carries out. Please read Section 9
(Privacy Rights (including EU and California Privacy Rights)) to learn
more about your rights.
· Sony discloses
the Collected Data when Sony engage a third party to process data on our
behalf, when such sharing is required by law, or in certain other situations.
Please read Section 4 (Who else has access to the Collected Data?)
to learn more.
· Sony may
transfer the Collected Data to the United States, Japan and other jurisdictions
that may not provide the same level of data protection as your home country.
Please read Section 6 (Transfer of the Collected Data internationally)
to learn more.
·
In
the context of Taiwan region, the TV referred in this privacy policy refers to
the TV and the LCD Monitor.
2. What information does Sony obtain about you?
Sony may receive the following data (collectively, the “Collected Data”) from you or automatically from third parties when you use the Application. If you wish to stop automatic data collection, you should disable this Application. Some of the Collected Data may be considered personal information under applicable law in your jurisdiction.
· UUID issued by Sony’s cloud service
· Authorization Code of Sony’s cloud service
· Amazon access token
The UUID issued by Sony’s cloud service is a unique number assigned to your Application in order to send Voice command from Amazon Alexa-compatible devices to your BRAVIA. Access token and Authorization Code of Sony’s cloud service are issued to your Application as a result of the authentication by Sony’s cloud service.
(i) To provide you with the services you have requested
We use the Access token and Authorization code of Sony’s cloud service to link your Amazon Alexa-compatible device and your TV.
Sony use Voice command information to process your request via Amazon Alexa-compatible device to do things like turning on/off your TV, channel switching, volume control and turning on/off installed application, and send the request to your TV.
It is necessary for Sony to use Collected Data to provide you with these services.
Please note that the legal basis under EU law for this processing is the necessity of performing our obligation in connection with the end user license agreement Sony has with you for your use of the Application.
(ii) Legitimate Interests
Sony also processes the Collected Data where it is necessary for Sony to enable its business or to pursue our legitimate interest of the efficient and effective provision of support to our customers. In particular, the Collected Data may be disclosed for information security purposes; to help content owners prevent copyright infringement. If our business is sold or integrated with another business, the Collected Data may be disclosed to our advisers and any prospective purchaser’s advisers and may be passed to the new owners of the business.
(iii) Required by Law
The Collected Data will be sent and stored in Sony’s server which is managed by Sony Electronics Inc., established in the United States, for the purposes of pursuing the activities outlined in Sections 2 and 3 above Sony has implemented appropriate safeguards to ensure these data transfers are made in compliance with applicable local laws.
If you contact your local Sony group companies in relation to questions about the Application, Sony may need to share the Collected Data with that Sony group companies to assist with your request. Sony may otherwise share Collected Data with Sony group companies for other purposes set out in this Privacy Policy.
(ii) Service Providers
Sony and Sony group companies may use third party service providers to store and process 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.
In the event that Sony or a Sony group company sell or transfer a portion or all of its business, the Collected Data may be transferred by Sony or such Sony group company to the purchasing or acquiring entity as part of the transaction, including any due diligence process connected to the sale or transfer. Sony will continue to ensure the confidentiality of the Collected Data before such transaction occurs, and after such transaction, Sony will delete the Collected Data as soon as reasonably practicable after such transaction.
(iv) Government Authorities/Law Enforcement Officials
The Collected Data may be disclosed to government authorities and/or law enforcement officials if required by the applicable laws.
(v) Other Unaffiliated Third Parties
Sony and Sony group companies 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 Sony believe necessary to comply with our legal obligations.
Sony will retain the Collected Data described in Section 2 for 6 months after your last access to this Application and Amazon Alexa-compatible device.
If you would like to delete the Collected Data collected via this Application, please open the TV Control with Smart Speakers application on your BRAVIA TV and then select [Home] > [TV Control with Smart Speakers] > [Settings] > [Privacy Policy] at any time to withdraw your consent to the privacy policy for the TV Control with Smart Speakers application. After you withdraw your consent, Sony will stop using the Collected Data, and the Collected Data will be deleted automatically after 6 months.
Alternatively, please contact us at the address set out below and Sony will respond to you in a reasonable time. Please note that Sony may be required to retain certain Collected Data by law. Where Sony no longer requires the Collected Data, it will be destroyed or de-identified in line with our internal information security policies.
The
Collected Data will be processed, stored and
transferred for the purposes outlined in Sections 3 from your country of
residence to Japan, EU (Ireland) and the United States. The Collected Data will
be processed by staff operating outside your country of residence who work for
us or for one of our service providers and may be seen by such staff in those
countries. Please refer to the following URL for an overview of
the legal system regarding protection of personal data in the country concerned.
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku
7. Security
Whenever Sony use service providers (including subcontractors) to
process the personal data, Sony confirms that such service providers (including
subcontractors) have adopted the necessary and appropriate security control
measures. In addition, Sony also expresses its basic policy on handling of
personal information in the “Sony Group Japan - Common Corporate Privacy
Policy” (https://www.sony.co.jp/privacy-policy/).
Please refer to such policy as well.
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries.
This Application is intended for a general audience; the Application 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 Sony with personal data/ personally identifiable information (as defined by applicable law) without your consent, you should contact us at the address set out 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 Collected Data which Sony is required by law to keep or has compelling legitimate interests in keeping. If you would like to exercise any of these rights, please contact us at the address as indicated below.
[Notice to EU, EEA and UK residents]
With regard to the Collected Data that Sony processes if you are located in the EU, EEA or the UK, you may have the following rights pursuant to Art. 15-18 and Art. 19-21 GDPR:
・You have the right to access (including a copy of) the Collected Data (Art. 15 GDPR); to correct, delete or restrict (stop any active) processing of the Collected Data (Art. 16-18 GDPR); and to obtain the Collected Data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this Collected Data to another controller (Art. 20 GDPR).
・In addition, you can object to the processing of the Collected Data in some circumstances (in particular, where Sony doesn’t have to process the data to meet a contractual or other legal requirement, or where Sony is using the data for direct marketing -Art. 21 GDPR).
・Where Sony has asked for your consent, you may withdraw consent at any time (Art.7 para 3 GDPR). If you ask to withdraw your consent to Sony processing your data, 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 data about another person, or if you ask us to delete information which Sony is required by law to keep or has compelling legitimate interests in keeping.
We would like to assist you with any queries or concerns you may have about our use of the Collected Data. However, you also have the right to complain to a supervisory authority for data protection in the country/region where you live, where you work, or where you consider that a breach of data protection law has occurred.
[Notice to California Residents]
If you reside in California, Sony are required to provide additional information to you about how Sony may use and disclose the Collected Data, and you may have additional rights with regard to how Sony use the Collected Data. Sony have included this California-specific information below.
CA Personal Information. Consistent with the section 2 (What Collected Data does Sony obtain about you?) above, Sony may collect certain categories and specific pieces of information about individuals that may be considered “personal information” (“CA Personal Information”) as defined by the California Consumer Privacy Act (“CCPA”).
・Identifiers: such as Access token of Sony’s cloud service and UUID issued by Sony’s cloud service
・Internet or Other Electronic Network Activity: such as voice command
Sources: Sony may collect certain categories of CA Personal Information from you and third party business partners as described in the section 1 (What Collected Data does Sony obtain?) above.
CA Personal Information Disclosed For Business Purposes.
· Sharing
your CA Personal Information for Business Purposes:
In the preceding twelve months, Sony may have shared the following categories
of CA Personal Information for business purposes: Identifiers and Internet or
Other Electronic Activity. This information may be shared for the purpose of
providing services to you, for legal compliance, or to protect legitimate
interests, in compliance with law.
· Sale
of CA Personal Information: In the preceding
twelve months, Sony have not sold (as defined under CCPA) CA Personal
Information.
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 Sony collect, use, or disclose; (ii) Deletion. Request deletion of your CA Personal Information; provided that to the extent permitted by applicable law, Sony 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 Sony have disclosed for business purposes within the preceding 12 months.
Exercising your California consumer rights. If you are a California resident and wish to exercise any of these rights or if you have questions regarding the CA Personal Information collected or shared with third parties, please: (a) contact us as described in the “Questions” section below with the specific nature of your request, referencing “Your California Privacy Rights – TV Control with Amazon Alexa ”; 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 Sony 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. Sony 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.
10. Additional Notice
[For Asia & Oceania Residents]
By using this Application, or providing us with any Collected Data, you fully understand and consent to the transfer of the Collected Data internationally, processing and storage of such Collected Data in the United States and other jurisdictions, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
This may impact your rights in your local jurisdiction and also in the applicable overseas jurisdiction(s). These overseas jurisdictions may also need to disclose your personal Collected Data to a third party, such as an overseas authority.
By using this Application, or providing us with any Collected Data,, you agree that you will not hold Sony or Sony Affiliates liable for any complaints or damages whatsoever relating to the processing of the Collected Data by an acquiring entity in the event a business transfer, as described in Section 4 of this Privacy Policy, takes place.
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 your personal Collected Data, please contact us at the address as indicated below.
FOR RESIDENTS IN THE EU AND THE EEA:
Sony Corporation, a Japanese company, is the controller for the Information. Our representative in the EU and the EEA is Sony Europe BV, 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 and EEA:
By email: privacyoffice.seu@sony.com
By post: Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom
You can also contact your local Sony group companies at https://sony-europe.com.
FOR RESIDENTS IN THE UK:
Sony Corporation, a Japanese company, is the controller for the Information. Our representative in the UK is Sony Europe BV, a Dutch company, whose UK branch has its business address in The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom.
By email: privacyoffice.seu@sony.com
By post: Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom
FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:
If you have any concerns about how we process your data, you can find our contact details below or on the website of your local Sony Group Companies at:
The US and Canada: privacy@am.Sony.com
For Mexico, Central and South America and the Caribbean:
Regional Latin America Privacy Office at https://www.Sony-latin.com/locale-selector
Africa and Middle East: https://www.Sony-mea.com/en/locale-selector
Asia & Oceania: http://www.Sony-asia.com/countryselector.html
Japan：http://www.sony.jp/support/
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