Privacy Policy
We take your privacy extremely seriously. This document (“Privacy Policy”)
describes what, why and how Sony Electronics (Singapore) Pte. Ltd and/or Sony International (Singapore) Ltd.
(collectively "Sony", "we" or "us")
collect and use your personal data, how we protect it and how you can contact
us.
Please
read this Privacy Policy carefully. By accessing our website, using any
services provided by Sony, signing up for any products and services provided by
Sony, submitting any information to us, or otherwise showing your agreement
thereon, you will be deemed to have agreed and consented to the terms of this
Privacy Policy.
We
reserve the right to amend, alter, change or modify
this Privacy Policy at any time and without prior notice. Any amendment,
alteration, change or modification will be posted from time to time on our
website.
1. Personal Data
1.1. In
this Privacy Policy, “Personal Data” means data, whether true or not,
about an individual who can be identified from that data, or from that data and
other information to which the organisation has or is likely to have access.
2. Collection
of Personal Data
We may collect your Personal Data in several different ways. Sometimes,
we or our authorized representative may collect your Personal Data from other
sources.
2.1 Information that we may collect
directly from you:
2.1.1 Whenever
you interact with Sony, you may be asked to provide us your Personal Data. For
example:
a)
Some of our services require you to create an
account, such as our My Sony, Sony Store Online, Sony Digital Workshop, and
Alpha Universe. When creating your accounts, we may ask you to provide a range
of information, such as your name, date of birth, contact details, interests
and account and newsletter preferences.
b)
When you purchase, register, send for repair or
return one of our products, we may record the call or chat and/or ask you to
provide information such as your contact details, delivery date and place of
purchase and payment information.
c)
When you contact our customer service centres for
assistance, we may keep information about the conversation, including your
name, contact details, the product(s) you bought, the reason to why you
contacted us and the advice we gave you.
d)
When you join one of our loyalty programs, we may
collect information relating to your use of the loyalty program and the rewards
that you claim.
e)
When you visit us at a public event, such as trade
show or exhibition or participate in one of our surveys, competitions, prize
draws or workshops, we may ask for information, such as your business card,
name, contact details, interests and preferences.
f)
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.
g)
When you participate in surveys and research, we
may ask you for information, such as your email address and information about
you.
h)
When you apply for a job position at Sony, we may
ask you for information such as your name, contact details, education
and employment history.
i)
When you submit your Personal Data to us for any
other reason.
2.1.2 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.
2.1.3 You
are not required to provide the Personal Data. However, if you do not do so, we
may not be able to provide you with our products or services, communicate with
you or respond to your enquiries. You should ensure that all Personal Data
submitted to us is complete, accurate, true and
correct because it may result in our inability to provide you with the products
and services you have requested.
2.1.4 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
required consent of the third party to provide us with their Personal Data.
2.2 Information that we may collect from
other sources:
2.2.1 We
may also collect your Personal Data from publicly available sources and third
parties, including:
a)
When you seek to make a purchase from us, we may
carry out credit and financial checks to ensure payment is not made
fraudulently and that you have a suitable credit rating.
b)
If you purchase products or services from a Sony
Centre or other retailer, we may receive certain information about your
purchase from that retailer.
c)
We may also receive information about you from
other Sony group companies that you interact with. In
particular, when you link your accounts for certain Sony group services.
d)
When carrying out business to business sales
calls, we may use business contact details that are publicly available.
e)
When carrying out research and development, we may
use information about you that are publicly available.
2.3 Information
we may collect in relation to social networks
2.3.1 If
you use any of our social network applications, pages or plugins or you use one
of our products or services that allow interaction with social networks, we may
receive information relating to your social network accounts. For instance:
a)
If you log-in to one of our websites or services
using your social network account, we may receive basic details from your
social network profile. The basic details we receive may depend on your social
network account privacy settings, however, they might include your social
network ID, name, profile picture, gender and locale.
We may also receive additional information from your profile if you give us
permission to access it.
b)
If you click on a 'like', '+1' or 'tweet' or
similar button in one of our websites or services, we may record the fact that
you have done so. In addition, the content that you are viewing may be posted
to your social network profile or feed. We may receive information about
further interactions with this posted content (for example, if your contacts
click on a link in the posted content), which we may associate with the details
that we store about you.
c)
If you 'like', '+1' or similar one of our pages on
a social network site, we may receive information about your social network profile,
depending on your social network account privacy settings.
d)
For more information and for details about how you
can control access to your social network profile, you should view the privacy
policy and other guidance available on your social network’s website.
2.4 Information we may collect when you use
websites, products and services from Sony
2.4.1 Some
of our websites, internet-enabled products and online services provide Sony
with information about your use of them, including:
a)
Details of the content that you view and interact
with. For example, when you use our website, we may collect information about
your visit, such as your browser software, which pages you view and which items
you ‘clicked’ on or added to your shopping basket.
b)
Service, product or
server logs, which hold information about your use of our service, product or
websites, such as your IP address, browser information (including HTTP user
agent strings), HTTP client request information and the time and location of
your activities, domain, device and application settings, errors and hardware
activity.
c)
Device information such as your device ID(s)
and/or information about where your device is physically located. For example,
when you are using a geo-location service or application and you have provided
consent to your location being shared.
d)
Interests and preferences that you specify during
setup of the Internet enabled product or service.
e)
Communications that you have with our customer
service centres or other Sony personnel may be monitored and logged.
f)
In general, this information is collected using
digital identifiers such as a device number, browser cookie or your IP address.
These identifiers are used to distinguish the information provided by your
browser or device from that of another user’s browser or device,
g)
We may associate the collected information with
one or more of your accounts, if for instance you are logged into a service
when the information is collected.
3. Purpose of Collection, Use and
Disclosure of Your Personal Data
3.1
Generally, we collect, use and disclose your Personal Data for the following
purposes:
3.1.1 Service provision
We may use personal information to provide services to you including:
a)
To provide you with a product or service you have
requested, including checking that a payment is not made fraudulently,
delivering your purchase or repaired products to you
or ensuring that you benefit from any relevant special offer or promotion (and
fulfil its obligations under any other agreement it may have with you).
b)
To facilitate and process your searches and
requests for information when you contact us about Sony and its products and
services.
c)
To resolve complaints, respond, and handle
requests and enquiries.
d)
To provide customer care, warranty, returns and
other after sales services.
e)
To verify your identity when you contact us.
f)
To provide our checkout assistance service. When
you use our online stores, details of any products that you seek to purchase and your email address may be collected as you fill
in the checkout form. If you do not complete your purchase, we may contact you
using these details to offer our assistance (in case, for instance, you were
suffering from technical difficulties). This is an optional service. You can
choose not to receive our checkout assistance emails at any time by following
the link at the bottom of each assistance email.
3.1.2 Product and service development
We may use Personal Data for product and service development purposes
such as:
a)
For staff training and quality assurance purposes,
particularly in relation to our customer relations staff at our call, email and other support centres. For example, we may monitor
and record your phone calls and customer-facing interaction.
b)
To measure our performance, troubleshoot and
improve and enhance our products and services and effectiveness, fix errors, or
ask for your opinions on Sony products and services and conducting product
surveys.
c)
To carry out research and development and
statistical analysis and marketing research activities to and create and improve new and existing Sony products and services,
recommendations, advertisements and other
communications and learn more about customers in general.
3.1.3 Marketing
We will use your Personal Data to offer you products and services we believe
may interest you. These products and services may be offered by us, our related
companies, our other business partners or our service
providers. Where you receive electronic
marketing communications from us, you may opt out of receiving further marketing
communications by following the opt-out instructions provided in the
communication.
Scenarios that we may use your Personal Data for marketing purposes
include:
a)
To provide you with newsletters and other
communications by post, email, telephone, text message (SMS), social network,
or instant message if you have provided your prior consent or we are otherwise
permitted to do so under applicable law. These communications may include, for
instance, details about the latest Sony products and services, including
upgrades and special offers in which you may be interested.
b)
Conduct prize draws, contests and organize any
other promotional offers or events.
c)
Show you personalised content, recommendations and
advertisements and more effectively target Sony stores, services, content,
recommendations, advertisements and communications.
You may notice this personalisation and targeting when you use Sony products
and services, when we contact you with marketing communications and when you
visit our and third party websites and services that
show advertisements from us or our advertising partners (for example, you might
see an advertisement for a product that you have recently viewed on one of our
websites). The personalisation and targeting that you see on our websites or in
our online advertisements and communications may make use of your ID or cookies
set by us or our third party advertising partners. In
other cases, our services may have specific settings to control personalised
content and you should consult the privacy policy of the relevant service for
more information.
d)
Create anonymous, aggregated statistics about the
use of our websites, products, services and loyalty
programs, which we may share with third parties and/or make available to the
public.
e)
Use product reviews, comments
or content you have uploaded to our websites or services and made publicly
visible to link to, publish or publicise elsewhere including in our own
advertisements. Each time you create or reply to a post or thread on a website
forum from Sony, in addition to providing this forum service, we may also
record the forum name and the time and date of your post or thread with your
account details. We do this to better understand the ‘typical users’ of our
forums and to select or tailor our marketing communications to reflect your
forum activity. We do not use the content of your forum posts or threads for
these additional purposes.
3.1.4 Security, fraud prevention and
investigation
a)
We may use your Personal Data collected from
monitoring our websites, online services and emails
for security purposes. We may also use your Personal Data to analyze, troubleshoot, investigate, handle, or resolve any
security matters or any vulnerability. This information may be passed to the
police or to other appropriate authorities.
b)
We may use Personal Data to prevent, detect, and
investigate commercial crime, dispute or fraud, to
investigate any violations of our policies, and to conduct audit, due diligence
or to analyze, prevent and manage commercial risks to
Sony. For example, we may use your information such as your device ID(s) to
ensure that any vouchers or discounts relating to any promotions or campaigns
are not being redeemed fraudulently, and to check that a payment is not made
fraudulently.
c)
We may also use your Personal Data to comply with
applicable laws, regulations and court orders and to
comply with valid legal information requests from such bodies. We may use your
Personal Data to enforce or defend the legal rights of any Sony group company
or the terms and conditions of any Sony product or service including obtaining
legal advice and dispute resolution.
3.1.5 Other purposes
a)
We may use your Personal Data for other purposes
which are reasonably related to the above purposes.
b)
When you apply for a job position at Sony, we will
use your Personal Data for recruitment purposes.
c)
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 those additional purposes as well, unless we
have specifically notified you otherwise.
d)
We may use your Personal Data for managing the
administrative and business operations of Sony and complying with internal
policies and procedures.
e)
We may use your Personal
Data to facilitate business asset transactions (which may extend to any
mergers, acquisitions or asset sales) involving any of
the related corporations or affiliates of Sony.
f)
We may process your Personal Data using an artificial
intelligence or automated decision-making tool for the purposes specified
herein. We will not do so if the activity is prohibited by local laws.
g)
Your Personal Data may also be combined or linked
via a unique identifier, such as a cookie, account number, email address and we
may also match any of your Personal Data for any of the purposes listed herein.
It is for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to
provide a more seamless customer support whenever you contact us and to provide
you with better, personalised services, content, marketing and advertisements.
4. Processing
of Children Data
4.1 We
consider a child to be anyone under the age of 13. We do not knowingly seek or collect
Personal Data from or about children without the consent of a parent or
guardian.
4.2 If
we become aware that Personal Data that has been submitted to us relates to a
child without the consent of a parent or guardian, we will use reasonable
efforts to:
a)
Delete that Personal Data from its files as soon
as possible.
b)
Ensure, where deletion is not possible, that this
Personal Data is not used further for any purpose, nor disclosed further to any
third party.
c)
Any parent or guardian with queries regarding our
processing of personal information relating to their child should contact us
using the details provided at the end of this Privacy Policy.
5. Retention of your
Personal Data
5.1 We will only retain your Personal Data for as long as is
reasonably necessary for the various purposes set out in this Privacy Policy or
to otherwise comply with any applicable laws and regulations concerning the
mandatory retention of certain types of information.
6. Disclosing
and Transferring of Personal Data
6.1 Subject
to the provisions of any applicable law, we may disclose or transfer your
Personal Data to the following parties for the purposes listed above:
a)
Sony’s related corporations or affiliates and
their employees to provide content, products and services to you or Sony.
b)
agents, contractors or third
party service providers who provide services to Sony.
c)
commercial shops and retailers in relation to
providing rewards and benefits.
d)
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.
e)
our professional advisers such as auditors,
financial advisers and lawyers.
f)
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.
g)
any other party to whom you specifically authorise
us to disclose your Personal Data.
6.2 Some
of the recipients may be outside of Singapore such as Japan, United Arab
Emirates, United Kingdom, United States of America, India, and China. We use a
variety of legal mechanisms, including data sharing agreements, to ensure
adequate level of protection of your Personal Data. It is deemed that you
consent and agree to Sony transferring your Personal Data outside of Singapore
for any of the purposes as listed above. If you have any questions or concerns,
please contact us using the details provided at the end of this Privacy Policy.
7. Security measures
7.1 We
take appropriate and commercially reasonable technical, physical, and
administrative measures to protect your Personal Data from misuse or
accidental, unlawful or unauthorised destruction,
loss, alteration, disclosure, acquisition or access in accordance with
applicable laws. These processes and systems include:
b)
Putting in place physical, electronic and procedural safeguards in line with industry
standards.
c)
requiring all employees to complete training about
information security.
8. Cookies, web beacons and embedded
scripts
8.1 In
order to improve our services to you, we sometimes use automated tracking
devices such as a “cookie”. A cookie is a small amount of data that our web
server sends to your web browser when you visit certain parts of our website
and the use of which is intended to assist our understanding of your interest
in our website. We may use the cookies to personalise the content,
recommendations, advertisements and communications
delivered to you so that they are more relevant to you and your interests. For
example, you may see an advertisement for a product that you have recently
viewed on our website. Please note that the cookies do not personally identify
users although they do identify a user’s browser. You can always choose to
disable cookies from being stored on your computer by changing your browser
settings. Disabling cookies however, may result in a
limited experience of our functionality and services and in some cases may mean
that we are unable to provide you with the services, or parts of the services,
that you have requested. Some of our business partners whose content is
incorporated into or linked to from the website may also use cookies. However, we
have no access to or control over these cookies or websites.
8.2 A
“web beacon” (also known as image tag, pixel tag, clear GIF
or web bug) is a small piece of code used to collect advertising data, such as
counting page views, promotion views or advertising responses. Web beacons or
similar technologies may be used for various purposes, including, without
limitation, to count visitors to our websites and to monitor how users navigate
our websites.
8.3 An
“embedded script” is programming code that is designed to collect information
about your interactions with our websites, such as the links you click on. The
code is temporarily downloaded onto your device from our server or a
third-party service provider, is active only while you are connected our websites,
and is deactivated or deleted thereafter.
9. Data subject rights
9.1 Under
the Personal Data Protection Act (“PDPA”) and its subsidiary legislation, as a
data subject you have the right to:
a)
be informed of the purposes for which your Personal
Data will be processed, the policies and practices that are necessary for Sony
to meet its key obligations under the PDPA;
b)
access your Personal Data;
c)
object to or withdraw consent for your Personal
Data being processed; and
d)
rectify any inaccuracy or error in your Personal Data;
10. Contact
10.1 If you have any questions, comments, concerns, or requests to withdraw your consent, make access or corrections to your Personal Data records or exercise any of your rights, you may contact us as follows:
Online Request
Form: Click Here
Write in: Data Protection Officer
Sony Electronics Asia
Pacific Pte. Ltd. /
Sony Electronics
(Singapore) Pte. Ltd. /
Sony International
(Singapore) Ltd.
1 Venture Avenue, #04-06
Perennial Business City, Singapore 608521
We will make our best effort to respond to your queries and/or requests within 30 days.
10.2 If
you withdraw your consent to any or all use of your Personal Data, depending on
the nature of your request, we may not be able to continue to provide its products
and/or services to you. In addition, there are some circumstances in which we
are not required to give you access to your personal information.
If you
remain unsatisfied with the way in which we have handled your privacy issue,
you may contact the Personal Data Protection Commission.
Updated: 1 August 2024 - Names of Sony entities