Privacy
Policy
We take your privacy extremely seriously. This
document (“Privacy Policy”) describes what, why and how Sony (Malaysia)
Sdn. Bhd. (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:-
1.1.1
Any data, whether true or false, which can be related
to a specific identifiable individual;
1.1.2
Your personal details, including details relating to other person(s) who may be identified from the data;
1.1.3
The contents of all information obtained from the
membership and/or VIP forms and/or document(s) collected by us;
1.1.4
Other information which is available to us.
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
When we use
personal information to offer our products and services to you, the processing
is based on an agreement between you and Sony. 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.
g)
To process your e-Invoice request in accordance with Inland Revenue
Board of Malaysia (IRBM) guidelines.
3.1.2 Product
and service development
We work
constantly to improve our products and services. We either base this processing
on our legitimate interests to develop our products and services to better meet
customer requirements, to ensure data quality, to develop identity management,
and to strengthen network and information security, or on your prior consent.
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.
When we use
Personal Data for marketing purposes, we base the processing on either our
legitimate interests to know our customers, keep you up-to-date
about Sony's latest products and services, and to personalise your customer
experience, or on your prior consent, e.g. for sending marketing messages and
to personalise your customer experience.
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. We base this processing on our
legitimate interests to protect you and our company, systems, employees and partners, or on a legal obligation to
cooperate with competent 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. In this case, we base the processing of personal information on
our legitimate interest to prevent fraud and to provide benefits only to our
customers.
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. In this case, we base the processing on a
legal obligation to which Sony is subject or on our legitimate interest to
defend our legal rights.
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. We base this processing on
consent.
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. We base this processing on legitimate interests.
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. We base this
processing on consent.
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 the 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 18. 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
Malaysia such as Japan, Singapore, 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 Malaysia 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
Personal Data Protection Act 2010, as a data subject you have the right to:
a)
have your data deleted or corrected where it is inaccurate;
b)
access your data which we process and keep with us;
c)
stop any of our new promotional products sent to you;
d)
withdraw your consent for us to process your personal
data.
10. Contact
10.1 If you have any questions, comments, concerns, or requests to
withdraw your consent, delete, make access or corrections to your Personal Data records
or exercise any of your rights, you may contact us as follows:
We will make our best
effort to respond to your queries and/or requests within 21 days.
There is no charge for
requesting access to your personal information, but we may require you to meet
our reasonable costs in providing you with access (such as photocopying costs
or costs for time spent on collating large amounts of material).
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
government authority.