Last revised date: February 2023
This privacy policy describes how Sony Electronics Inc. ("SEL") uses the information it collects from you and your TV when you register your TV through the “My BRAVIA” (formerly known as “Bonus Offer”) Application (the “App”) available through the TV. This privacy policy is limited to your use of this registration and promotion application. It does not govern SEL's or its affiliates’ collection of information through your use of the 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 SEL COLLECTS
We collect information from you directly, automatically when you use the App, and sometimes from third parties. Some of this information may be considered “personal information” or “personal data,” and some of which may be considered “sensitive” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name, phone number, e-mail address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. In some cases, we may de-identify, aggregate, or pseudonymize personal information so that it can no longer identify you directly. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law.
When you use the App, SEL 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, SEL 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"). If we combine information, we consider to be non-personal with Personal Information, we will treat that combined information as Personal Information under this Privacy Policy. 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 SEL USES DATA
Surveys
From time to time, SEL may ask you whether you would like to participate in a survey sponsored by us or another Sony group company and we will collect the information you provide if you choose to respond to that survey. We may use the Survey Data for purposes specified in each survey or this privacy policy. You can decide not to participate in the survey or discontinue at any point during the survey.
Processing activities in connection with providing the App to you and Product Registration
SEL 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.
Marketing and Advertising
SEL may use your App Log data, Device Identifiers and Survey Data, to serve targeted or personalized advertisements to you on your device and elsewhere online such as third-party websites including social networks, deliver marketing communications or send you emails with new product information, articles, offers and promotions.
In addition, subject to your consent, we may also use the above information and your Personal Information, to email you newsletters and special offers for products and services that may be of interest to you.
For these purposes, SEL may access and use data collected by Sony Affiliates through other Sony devices, such as the TV Log data (subject to your consent, TV data shared with SEL in accordance with Sony Corporation's privacy policy for BRAVIA) or other applications that you may use, and this data may be combined with the data SEL collects about you.
You can unsubscribe from receiving emails at any time by following the instructions in the emails.
For more information regarding advertising and your choices, please refer to the Advertising section below.
Sharing data with Sony Corporation forproduct improvement
Subject to your consent, we may share App Log data and Survey Data with Sony Corporation for purposes of product and service development and improvement. Accordingly, Sony Corporation may use the data to develop and improve their TVs, applications (including the App) and device settings by analyzing customer use patterns.
You can withdraw your consent above at any time via the [Settings] menu in the App.
HOW SEL SHARES INFORMATION
Except as may be prohibited by law, we may share non-personal information, such as aggregate user statistics, hashed or otherwise de-identified or pseudonymized information with Sony Corporation or other Sony group companies and third parties in our discretion.
SEL shares information about you with third parties working on our behalf to provide a feature or service to us or to you, such as providing customer support services, managing e-mail communications with you, serving advertisements to you, and for internal business purposes.
SEL may share information about you with Sony Corporation as an independent controller for the purposes described in “Sharing data with Sony Corporation for product improvement”.
If you contact SEL in relation to queries about this App, we may need to share information about you with Sony Corporation to assist with your request.
The information SEL 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.
SEL may share information about you with its parent, or its subsidiaries and affiliates, primarily for business and operational purposes, including sharing your email address with Sony of Canada, Ltd. for marketing purposes where you have given your consent.
If our business is sold or integrated with another business, the information SEL 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 SEL TRANSFER INFORMATION?
Sony Electronics Inc. is a company incorporated in the United States and its servers may be located in various countries around the world (including Japan, the United States. Canada and others). By agreeing to register your TV and/or receive e-mail messages, you consent to the transfer, processing, and storage of your information in and to Japan, the United States, Canada and other countries which may not have the same level of legal protection for data as the laws in your country.
Data Retention
SEL will continue to retain the Personal Information and Device Identifiers for no more than 6 months after the termination of use of the App, unless we are permitted or required under applicable law to retain the data for a longer period.
With regard to the App Log data, SEL will apply a maximum of 6 months retention period from the date of the collection.
SEL 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.
ADVERTISING, WHAT RIGHTS YOU HAVE, AND HOW YOU CAN EXERCISE THEM
You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of your TV, such as administrative and services announcements, and these transactional account messages will be unaffected if you choose to opt out from marketing e-mails.
We may share de-identified data with our network advertisers or others in order to target advertisements to you or limit the number of times you see advertisements. Please be aware that if you choose to block cookies, some advertising preferences dependent on cookies may not be able to be respected and that even if you opt out of targeted online advertising, you will continue to receive generic ads online.
In addition, some service providers we use to perform advertising and analytics services may be members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, and http://www.aboutads.info/choices/, which provide information regarding targeted advertising and offer an “opt-out” by companies participating in the program(s).
Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our application does not respond to such signals.
HOW SEL PROTECTS INFORMATION
SEL 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.
CHILDREN’S PRIVACY
SEL is committed to complying with all applicable laws and regulations regarding the collection, storage and use of data concerning children, including the Children's Online Privacy Protection Act in the United States. This App 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. If you are a parent or guardian and are concerned that your child has provided SEL with personal information (as defined by applicable law), you should contact us as indicated below.
CHANGES TO PRIVACY POLICY
SEL 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 App or through contact information you have provided. Your continued use of the App on or after the posted effective date will constitute acceptance of those changes to the extent allowed by applicable law. However, SEL will provide notice and obtain your consent if required.
NOTICE TO CALIFORNIA RESIDENTS/OTHER STATE RIGHTS:
If you reside in California, we are required to provide additional information to you about how we collect, use and disclose information, and you have the right to request that we provide you with access to the data that we have collected, that we delete your data, to correct any inaccurate data that we may hold about you, and to opt-out of any “sale” or “sharing” of personal information. For more information on your California privacy rights, please refer to:
https://electronics.sony.com/privacy-policy#DataPractices
California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information:
If you wish to exercise a right listed in this section, you may submit a request at: https://products.sel.sony.com/SEL/legal/DataRequests.html
“Do Not Sell or Share My Personal Information.” If we “sell” your CA Personal Information to a third party or “share” your CA Personal Information for purposes of cross-context behavioral advertising, you have the right to opt-out of the sale or sharing of your CA Personal Information. If you wish to exercise this right, you may submit a request at: https://products.sel.sony.com/SEL/legal/DNSRequest.html.
We do not knowingly collect personal information under the age of 16. Accordingly, we do not knowingly “sell” or “share” the personal information of users under the age of 16.
If you use certain SEL websites, you may need to disable sharing through cookies set by third parties on those SEL websites. To manage your cookie preferences, please refer to the “Manage Cookies” link on the cookie banner or in the footer for the applicable website and ensure that “Targeting Cookies” are disabled.
“Limit the Use and Disclosure of Sensitive Personal Information.” A business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions. SEL’s use and disclosure of Sensitive Personal Information is not used for such purposes and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
Exercising Your Rights. If you are a California resident and wish to exercise any of these rights, please refer to the links above, or you may also 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 we can verify your identity, and we may require that you validate your request. Please note that you are limited by law in the number of requests you may submit per year.
We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, or in connection with promotions and other offerings, based upon you exercising your rights with respect to your CA Personal Information.
Data Retention. We retain all categories of Personal Information for as long as it is reasonably necessary for the purposes outlined in our California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using the App or continuing to interact with us.
Data Reporting. please refer to:
https://electronics.sony.com/DSR-metrics to access our data reporting metrics for the previous calendar year.
Notice of Financial Incentive. Under California regulations, certain aspects of any loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We collect Personal Information from you, such as your name and email in connection with this App for a number of reasons. This includes to: register your TV and provide benefits and special offers to you.
To the extent that we provide offers that may be considered a financial incentive because it is part of a program that is directly or reasonably related to the collection, deletion or retention of consumer Personal Information, the value is reasonably related to the overall value we receive from the Personal Information participants provide specific to the program minus the costs and expenses we incur in providing the program.
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 in the California Probate Code. We may require additional proof of authority or may need to contact you directly to validate the request.
Additional Notice to California Residents:
If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to whom Sony may have disclosed, within the past year, personal information pertaining to you and your family for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to privacy@am.sony.com and include your name, email address, and a reference to “Your California Privacy Rights – BRAVIA APP”. We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
Notice to Virginia Residents:
We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
Virginia Consumers have the following rights with respect to their personal data subject to the meanings and exceptions set forth in the Virginia Consumer Data Protection Act (“VCDPA”):
If you are a Virginia Consumer and would like to exercise any of these rights, please complete the form here: Data Requests (https://products.sel.sony.com/SEL/legal/DataRequests.html).
Opt-out of Targeted Advertising: Virginia Consumers have the right to opt-out out of the processing of your Personal Data for the purposes of targeted advertising. SEL engages in online advertising and analytics practices that may be considered “targeted advertising” under the VCDPA. To exercise your rights to opt-out of targeted advertising, you may submit a request here: Opt-out of Targeted Advertising (https://products.sel.sony.com/SEL/legal/DNSRequest.html).
In addition, you may need to disable sharing through cookies set by third parties on certain SEL websites which may be considered targeted advertising under the VCDPA. To manage your cookie preferences, please refer to the “Manage Cookies” link on the cookie banner or in the footer for the applicable website and ensure that “Targeting Cookies” are disabled.
While the VCDPA also permits you to opt-out of the sale of your Personal Data, at this time we do not engage in the sale of Personal Data to third parties for monetary compensation. Similarly, we do not process your Personal Data for purposes of profiling as set forth in the VCDPA that would require such an opt-out.
VCDPA Appeals
Pursuant to the VCDPA, if, for any reason, you would like to appeal a decision made by us relating to your request, you have the right to submit an appeal and can do so by completing this form: Data Requests (https://products.sel.sony.com/SEL/legal/DataRequests.html). Please include your full name, the basis for your appeal, and any additional information to consider.
Notice to Nevada Residents:
If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. We do not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if we were to engage in such a sale in the future, you may submit your request in writing to: privacy@am.sony.com. Your request must reference “BRAVIA APP - Nevada rights” and include your name, mailing address, zip code, and email address. Your request is subject to verification of your identity by us and validation of your request. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. We will respond to valid requests within sixty (60) days.
Other State Rights:
Starting in 2023, if you are a resident of Colorado, Connecticut or Utah, you may have certain rights with respect to your personal information. For more information about your rights and how to exercise them, please refer to: https://products.sel.sony.com/SEL/legal/DataRequests.html
HOW CAN YOU GET IN CONTACT WITH SEL IF YOU HAVE QUESTIONS?
If you have any concerns about how we process your data, you can contact us as follows:
United States: Write to us by email: at privacy@am.sony.com, or by mail at: Sony Electronics Inc., Attn: Personal Information Management Office, 115 W. Century Road Suite 250, Paramus, New Jersey 07652 or call our dedicated privacy line: 1-833-681-9900
Canada: Write to us at: Sony of Canada Ltd., Attn: Privacy Officer, Law Department, 2235 Shepard Avenue East, Suite 700 Toronto, ON M2J 5B5 or call our dedicated privacy line toll-free (within Canada): 1-888-494-7669