Privacy
Policy
We take your
privacy extremely seriously. This document (“Privacy Policy”) describes
what, why and how Sony Philippines, Incorporated (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 any information whether recorded
in a material form or not, from which the identity of an individual is apparent
or can be reasonably and directly ascertained by the entity holding the
information, or when put together with other information would directly and certainly
identify an individual.
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 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.
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 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 Philippines 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.
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
Republic Act 10173, the Data Privacy Act of 2012 and its subsidiary
legislation, as a data subject you have the right to:
a)
be informed that your
Personal Data will be, are being, or were, collected and processed;
b)
access your
Personal Data;
c)
object to your
Personal Data being processed;
d)
suspend,
withdraw or order the blocking, removal or destruction of your Personal Data;
e)
claim
compensation if you suffer damages due to inaccurate, incomplete, outdated,
false, unlawfully obtained or unauthorized use of Personal Data;
f)
rectify any
inaccuracy or error in your Personal Data; and
g)
obtain and
electronically move, copy or transfer your Personal Data in a secure manner,
for further use.
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:
Sony Philippines Incorporated
Unit B&C 10th Floor and 11th Floor Inoza Tower, 40th Street, Bonifacio Global City, Fort Bonifacio, City of Taguig, Philippines 1634.
Request
Form: Click Here
By email: PI_Inquiry.PH@ap.sony.com
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
National Privacy Commission.
