Dear Customer
We at Sony Middle East and Africa FZE (referred herein as "Sony", "we", "us", "our") value every person's right to privacy and strive to protect your Personal Information. This Privacy Policy will inform you as to what Personal Information is collected from you by us or on our behalf when you register for and use Sony Loyalty App mobile application (Loyalty App), and the way we use and dispose of it and also the way you can control your Personal Information.
By registering for and using Loyalty App, you consent to the data practices described in this Privacy Policy as well as any other applicable terms and conditions as may be communicated to you. If you do not agree to any part of this Privacy Policy, then you should stop accessing the Loyalty App. Your engagement with us or our affiliates in relation to registration and usage of Loyalty App constitutes your consent to terms and conditions of this Privacy Policy. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or Processing Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
In order to serve you better, we may update this Privacy Policy from time to time. We encourage you to review this Privacy Policy each time you use the Loyalty App so as to be informed of any changes to this Privacy Policy.
Please also use the Glossary (section 10 below) to understand the meaning of some of the terms used in this Privacy Policy.
This Privacy Policy aims to give you information on how we or our affiliates collect and Process your Personal Information when you register and use Loyalty App, including any information you may provide by completing online registration forms through the Loyalty App .
Sony is the Controller and responsible for your Personal Information.
We have appointed a privacy officer (PO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the PO using the details set out below.
If you have any questions about this Privacy Policy or our privacy practices, please contact our PO in the following ways:
You have the right to make a complaint at any time to the relevant Data Protection Authority. We would, however, appreciate the chance to deal with your concerns before you approach the relevant Data Protection Authority so please contact us in the first instance.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
We may also collect, use and share Aggregated Information such as statistical or demographic data for any purpose. Aggregated Information could be derived from your Personal Information but is not considered Personal Information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific Loyalty App feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, process your registration for you to use Loyalty App).
We use different methods to collect Personal Information from and about you including through:
You may give us your Identity, Contact by filling in online forms through the Loyalty App.
We do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information, please contact us.
Sony and our affiliates collect and use Personal Information to provide you the service you have requested (this being earning and redemption of points in Sony MEA partner store through purchase of “SONY” branded products in UAE).
We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may Process your Personal Information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal basis we are relying on to Process your Personal Information where more than one basis has been set out in the table below.
Purpose/Activity | Type of Personal Information | Lawful basis for Processing including basis of legitimate interest |
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To enable you to register on Loyalty App |
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To administer and protect our business and this Loyalty App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
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To use data analytics to improve our Loyalty App, products/services, marketing, customer relationships and experiences |
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We may use your Identity, Contact, Technical, and Usage Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested informati
We do not share your Personal Information with any third party for their marketing purposes.
You can ask us or third parties to stop sending you any marketing messages at any time by contacting us at any time.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will only retain Personal Information 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.
We share your Personal Information with third parties for the purposes set out in the table in section 4.b above. These are:
In some cases, your Personal Information may also be disclosed to third parties by us or our affiliates when this is required to or where it is appropriate to comply with the law (e.g. if required by law enforcement authorities, or in terms of a lawful subpoena, warrant or court order); to enforce or apply this Privacy Policy or our other policies or agreements; to protect our or our users’ rights, property or safety; to protect our users from fraudulent, abusive, or unlawful use of the Loyalty App; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires or justifies disclosure of Personal Information.
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to Process your Personal Information for specified purposes and in accordance with our instructions.
We share your Personal Information within the Sony Group. This will involve transferring your Personal Information outside your particular country. We ensure your Personal Information is protected by requiring all our group companies to follow the same rules when Processing your Personal Information.
Many of our external third parties may be based outside your country so their Processing of your Personal Information will involve a transfer of information outside your country.
By using this Loyalty App and completing registration, you agree to not being notified of details regarding the level of protection afforded to your Personal Information in the relevant country/countries.
We have put in place appropriate security measures to prevent your Personal Information from being lost, damaged, destroyed in an unauthorised way or accessed in an unauthorised way. Where possible, we have ensured that all information provided by you in an online form is processed in a closed environment and is not downloaded or In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only Process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so
Under certain circumstances, you have the following rights under applicable Data Protection Laws in relation to your Personal Information:
If you wish to exercise any of the rights set out above, please contact us.
We try to respond to all legitimate requests within a month from the date of receipt of your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated