1. Personal Data
1.2. Examples of such Personal Data you may provide to us includes (depending on the nature of your interaction with us) your name or other identification proofs, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any form you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
2.1. Sony may collect your Personal Data in several different ways. Please take care when submitting information to us, in particular when completing free text fields or uploading documents and other materials. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.
2.2. Whenever you interact with Sony, you may or may be asked to provide us your Personal Data. For example:
- when creating your accounts, signing up or subscribing for service updates, we may ask you to provide a range of information, such as your name, date of birth, contact details, interests and newsletter preferences;
- when you purchase, register, send for repair or return one of our products, we may record the call and/or ask you to provide information such as your contact details, delivery date and place of purchase and payment information;
- when you contact our customer service centres for assistance, we may keep information about the call, including your name, the product(s) you bought, the reason to why you contacted us and the advice we gave you;
- when you visit us at a public event, such as trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for information, such as your business card, name, contact details, interests and preferences;
- when you use our online services, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about for example, when you select the services that you wish to receive; and
- when you submit your Personal Data to us for any other reasons.
2.3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the purposes as listed below.
2.4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
3. Purpose of Collection, Use and Disclosure of Your Personal Data
3.1. Generally, Sony collects, uses, stores, processes and discloses your Personal Data for the following purposes:
3.2. In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
- resolving complaints and responding and handling requests and enquiries;
- providing customer care, warranty, returns and other after sales services;
- for staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other support centres;
- asking for your opinions on Sony products and services and conducting product surveys;
- facilitating and processing your searches and requests for information when you contact us about Sony and its products and services;
- conducting prize draws, contests and other promotional offers;
- managing the administrative and business operations of Sony and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the related corporations or affiliates of Sony;
- matching any Personal Data storedwhich relates to you for any of the purposes listed herein;
- analysing, investigating, handling, resolving any security matters or any vulnerability;
- preventing, detecting and investigating crime and analysing and managing commercial risks;
- providing media announcements and responses;
- monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- organising promotional events;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- conducting investigations relating to disputes, billing or fraud;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Sony (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
- any purposes which are reasonably related to the aforesaid.
4. Disclosing and Transferring Personal Data
4.1. Sony will take appropriate and commercially reasonable technical, physical, and administrative measures to protect any Personal Data it possesses or controls from misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access in accordance with the applicable Laws. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- Sony’s related corporations or affiliates and their employees to provide content, products and services to you or Sony;
- agents, contractors or third party service providers who provide services to Sony;
- trade partners in relation to providing rewards and benefits, if any;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of Sony’s related corporations or affiliates;
- our professional advisers such as auditors, financial advisers and lawyers;
- relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- any other party to whom you specifically authorise us to disclose your Personal Data.
4.2. You consent and agree to Sony transferring your Personal Data outside of India for any of the purposes as listed above.
[Note: Under Rule 7 of the Indian Privacy Rules, it is mandatory for the entity receiving personal information to maintain at least the same level of data protection standards as the transferor of personal data. As such, please consider if these are being complied with, or if (going forward) Sony should contractually specify that any overseas entity receiving such data abides by the same level of data protection standards.]
5. Data Retention
5.1. We will continue to retain your Personal Data for as long as is reasonably necessary for the various purposes set out in "Purpose of Collection, Use and Disclosure of Your Personal Data" section above, or if required to be retained under any applicable law. In case any of your Personal Data is no longer required by us, we take reasonable steps to destroy or anonymize any personal data after a reasonable period of time has elapsed. [Note: The policy is silent on the period for which Sony may retain the personal data. Under Indian Privacy Rules, an entity holding personal information cannot retain personal data for longer than is required, except for lawful purposes. Please consider if this provision is in accordance with Sony's internal retention, data handling policies, anonymisation controls, etc.]
7. Contact us
7.1. If you have any questions or feedback relating to your Personal Data or our Data Protection Policy, you can contact us
[Note:: As per Indian Privacy Rules, the data collector is required to appoint a “Grievance Officer”, to resolve any grievances of data subjects within one month from receiving them, and details of such grievance officer is to be provided to the data subject. The Grievance Officer can be based overseas. A fresh appointment need not be made to fill this position. An existing officer of Sony dealing with data privacy matters can handle these grievances.]
8. Access to your Personal Data and your rights
8.1. You have the following rights in respect of the Personal Data we collect from you:
- Right to review and update their information.
- Right to withdraw consent and/or request for its deletion.
8.2. Please contact us at [inset email/hyperlink] if you would like to exercise any of the rights available to you.
8.3. If you withdraw your consent, this may affect our ability to provide services and facilities to you.
[Note:: Indian Privacy Rules grant data subjects the right to review and update their information, option to withdraw consent and/ or request for its deletion.]