Last revised date: February 2023
This privacy policy describes how Sony Europe BV ("Sony EU") uses the information it collects from you and your TV when you register your TV through the “My BRAVIA” (formerly known as “Bonus Offer”) (the “App”) available through the TV. This privacy policy is limited to your use of this registration and promotion with and through the application. It does not govern Sony EU's or its affiliates’ collection of information through your use of the BRAVIA TV or other applications.
Please see Sony EU’s Privacy Policy (https://www.sony.co.uk/eu/pages/privacy/en_GB/privacy_policy.html) for information how we process your personal data inter alia in the course of BRAVIA TV or other applications.
The BRAVIA TV privacy policy, which was presented during initial TV setup, can be viewed on your TV under [Help] > [Privacy setting]. You can also go to [Help] > [Privacy setting], at any time, to withdraw consent you have given to our use of your data.
INFORMATION SONY EU COLLECTS
When you use the App, Sony EU collects information that identifies your specific TV, including Advertising IDs ("Device Identifiers"), as well as data regarding operation of the App and how you interact with the App, such as what selections you make on each screen, whether you reviewed the terms and conditions of a particular offer, responded to or selected an offer, and the time you spend in the App ("App Log"). When you register your TV or respond to an offer or survey, Sony EU will also collect some information that may be used to identify you as a specific person, such as your name and e-mail address ("Personal Information"). In addition, we may collect information about you, such as your interests and preferences with regard to current and future television-related products and services on the market, via survey (“Survey Data”).
HOW SONY EU USES DATA
Surveys
From time to time, Sony EU may ask you whether you would like to participate in one of our surveys and subject to your consent we will collect the information you provide. We may ask for information, such as your interests and preferences with regard to current and future television-related products and services on the market. You can decide not to participate in the survey or discontinue at any point during the survey.
You can withdraw your consent above at any time by following the instructions in the emails. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Also, you are not legally obliged to provide us with this information, however otherwise we may not be able to provide all services to you.
Processing activities in connection with providing the App to you
Sony EU may use the Personal Information, App Log data and Device Identifiers it collects to (i) register your product and provide the content and services that you request (ii) provide technical support services; and (iii) investigate and prevent fraud and other illegal activities or activities that violate our policies.
The legal basis for purpose (i) is fulfilment of a contract (Article 6 (1) (b) General Data Protection Regulation); for purposes (ii) and (iii) it is our legitimate interest to maintain secure services (Art. 6 (1)(f) General Data Protection Regulation).
General Marketing via Email
Subject to your consent (by selecting “I agree to receive marketing emails”), we process your email address, App Log and TV Log (TV data shared with Sony EU in accordance with Sony Corporation's privacy policy for BRAVIA) data, to email you special offers for products and services that may be of interest to you, deliver marketing communications or serve you with advertisements.
Please note that your consent forms the legal basis for Sony EU processing information about you for general marketing via email under EU-law (Article 6 (1) (a) General Data Protection Regulation). You can withdraw your consent above at any time by following the instructions in the emails. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Also, you are not legally obliged to provide us with this information, however otherwise we may not be able to provide all services to you.
Tailored Marketing via emails and/or contents displayed on your device
Subject to your consent (by selecting “I agree to get tailored marketing via emails and on my device or third party websites including social networks”), we will provide you with tailored recommendations about our products and services via emails or advertising banners displayed on your device or third party websites including social networks. For this purpose, we evaluate your preferences and interests we identify by using App log and TV log, Personal Information, Survey Data and Device Identifiers. Please note that these information may be used and combined with other data that Sony EU has collected from you across other Sony products and services that you may use.
You may notice this personalisation and targeting when you use Sony EU products and services, when Sony EU contacts you with marketing communications including email (for example, you might see an advertisement relevant to a product that you have recently used).
Please note that your consent forms the legal basis for Sony EU processing information about you for tailored marketing via emails and/or contents displayed on your device under EU-law (Article 6 (1) (a) General Data Protection Regulation). You can withdraw your consent above at any time as follows:
(i)Tailored emails
Following the instructions in the emails.
(ii)Tailored contents displayed on TV
Selecting "Setting menu" in the App.
The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Also, you are not legally obliged to provide us with this information, however otherwise we may not be able to provide all services to you.
Sharing data with Sony Corporation forProduct improvements
Subject to your consent (by selecting “App usage data may be shared with Sony Corporation to improve products/services”), we share your App Log data and Survey Data with Sony Corporation. Subsequently, Sony Corporation will develop and improve its TVs, applications and device settings by analysing customer use patterns.
Please note that your consent forms the legal basis for Sony EU processing information about you for improving/developing Sony Corporation’s products and services under EU-law (Article 6 (1) (a) General Data Protection Regulation). You can withdraw your consent above at any time by selecting "Setting menu” in the App.
The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Also, you are not legally obliged to provide us with this information, however otherwise we may not be able to provide all services to you.
HOW SONY EU SHARES INFORMATION
Sony EU shares information about you with third parties working on our behalf to provide a feature or service to us or to you.
Sony EU may share information about you with Sony Corporation as an independent controller for the purposes of “Sharing data with Sony Corporation for Product improvements”.
If you contact Sony EU in relation to queries about your TV, we may need to share information about you with Sony Corporation to assist with your request.
The information Sony EU collects may be shared with government authorities, law enforcement officials and content owners if required for the purposes above, if mandated by law or if required for us to protect our legitimate interests, or the interests of content owners or other users, in compliance with applicable law.
If our business is sold or integrated with another business, the information Sony EU collects may be disclosed to our advisers and any prospective purchaser’s advisers and may be passed to the new owners of the business.
WHERE DOES SONY EU TRANSFER INFORMATION?
The information about you will be processed, stored and transferred for the purposes outlined in “HOW SONY EU USES DATA” to countries/regions outside the European Economic Area (EEA) and/or your country/region of residence, including in particular Japan and the United States.
Where information is transferred out of the European Economic Area (EEA) to us or a third party in connection with the purposes set out in this Privacy Policy, we will, to the extent that no statutory level of security comparable to the European data protection laws exists in such countries/regions, adopt appropriate measures to ensure that your personal data will be adequately protected in these countries/regions. In particular, we may apply the standard contractual clauses published by the European Commission, which can be accessed https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en. Where the information is transferred to Japan, the adequate level of data protection is confirmed by the European Commission´s adequacy decision.
Data Retention
Sony EU will continue to retain the Personal Information and Device Identifiers for 6 months after the termination of use of the App unless permitted or required under applicable law.
With regard to App Log data and Survey Data, Sony EU will apply a maximum of 6 months retention period from the date of the collection.
Sony EU may retain information about you 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 information for specific periods.
HOW SONY EU PROTECTS INFORMATION
Sony EU takes commercially reasonable steps to protect and secure Personal Information. However, no data transmission over the Internet, by wireless transmission, or any electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect, and you provide your information at your own risk.
PRIVACY RIGHTS
In some countries/regions, you have certain rights with respect to information Sony EU holds about you. These may include the right to request a copy of information that Sony EU holds about you and/or the right to request that Sony EU amends, deletes, blocks/restricts or corrects such information if it is inaccurate. You may also have the right to ask us to provide some types of information to you, or another organisation nominated by you, in a structured and machine-readable format. In addition, you can object to the processing of information in some circumstances (in particular, where we don’t have to process information to meet a contractual or other legal requirement).
CHANGES TO PRIVACY POLICY
Sony EU reserves the right to change this Privacy Policy at any time and those changes will become effective immediately upon posting, unless otherwise stated. We may provide notice to you in the Application or through contact information you have provided. Your continued use of the Application on or after the posted effective date will constitute acceptance of those changes to the extent allowed by applicable law. However, Sony EU will provide notice and obtain your consent if required.
HOW CAN YOU GET IN CONTACT WITH SONY EU IF YOU HAVE QUESTIONS?
If you have any concerns about how we process your data, you can contact us as follows:
FOR RESIDENTS IN THE EU or Switzerland:
If you have a privacy concern, complaint or question, please contact Sony EU at privacyoffice.SEU@sony.com
You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at https://sony-europe.com.
FOR RESIDENTS IN THE UK:
If you have a privacy concern, complaint or question please contact Sony EU at: privacyoffice.SEU@sony.com
You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.