Privacy Policy in respect of Sony Loyalty App

Updated on 07 June 2021

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.

1. Important information and who we are
   1. Purpose of 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 .

   2. Controller

   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.

   3. Contact details

   If you have any questions about this Privacy Policy or our privacy practices, please contact our PO in the following ways:

   1. Full name of legal entity: Sony Middle East and Africa FZE
   2. Email address:Sony Customer Care
   3. Postal address: P.O. Box 16871, Jebel Ali Free Zone, Dubai, United Arab Emirates – for the attention of “Personal Information Management Office”.
   4. Telephone number: 8007669 (or if calling from outside the United Arab Emirates: +971 8007669).

   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.

   4. Your duty to inform us of changes

   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.

2. Information we collect from you
   1. General

   We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

   1. Identity Information includes first name, maiden name, last name, username or similar identifier.
   2. Contact Information includes email address.
   3. Technical Information includes internet protocol (IP) address, your login data, time zone setting, operating system and platform, and other technology on the devices you use to access Sony Loyalty App.
   4. Profile Information includes your username and password
   5. Usage Information n includes information about how you use Loyalty App.
   6. Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences

   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.

   2. If you fail to provide Personal Information

   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).

3. How is your Personal Information collected?

   We use different methods to collect Personal Information from and about you including through:

   1. Direct interactions

   You may give us your Identity, Contact by filling in online forms through the Loyalty App.

   2. Children under the age of 18

   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.

4. Use of your Personal Information
   1. Service provision

   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).

   2. Purposes for which we will use your Personal Information

   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
   To enable you to register on Loyalty App	Identity Contact	Performance of a contract with you; or Consent
   To administer and protect our business and this Loyalty App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation
   To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) Consent
   To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Usage Profile Marketing and Communications Technical	Necessary for our legitimate interests (to develop our products/services and grow our business) Consent
   To use data analytics to improve our Loyalty App, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Loyalty App updated and relevant, to develop our business and to inform our marketing strategy)

   3. Promotional offers from us

   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

   4. Third-party marketing

   We do not share your Personal Information with any third party for their marketing purposes.

   5. Opting out

   You can ask us or third parties to stop sending you any marketing messages at any time by contacting us at any time.

   6. Change of purpose

   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.

5. Retention and disclosure of Personal Information
   1. General

   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:

   1. SalesForce.com to make suggestions and recommendations (usually via email marketing communications) about our goods and service that may be of interest to you (please see 4.b above for more details);
   2. Facebook.com to deliver relevant content and advertisements about our goods and services that may be of interest to you (please see 4.b above for more details);

   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.

6. Retention period
   1. We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for or subsequently Processed, unless: the retention of the information is required or authorised by any legal or regulatory requirements; we reasonably require the information for lawful purposes relating to one of our functions or activities (for example in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you); the retention of the information is required by a contract entered into between us; or you consent to such retention of information.
7. Cross-border transfers of Personal Information
   1. Sony Group

   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.

   2. Third parties

   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.

   3. Use of this Loyalty App

   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.

8. Security
   1. Measures

   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.

   2. Cyber incident response

   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

9. Right to control your Personal Information
   1. Rights

   Under certain circumstances, you have the following rights under applicable Data Protection Laws in relation to your Personal Information:

   1. Notification that your Personal Information is being collected. When your Personal Information is collected, you have the right to be informed that your information is collected and where the information is not collected from you, you have the right to be informed of the source from whom/which it is collected.
   2. Notification of security compromises. Where reasonable grounds exist for us to believe that your Personal Information has been accessed or acquired by an unauthorised person, you have the right to be notified.
   3. Request access to your Personal Information. You have the right to confirm, free of charge, whether or not we hold any of your Personal Information, and to the extent that we do hold your information, to request a copy or description of that record free of charge. You will be required to provide adequate proof of your identity so that we can confirm your identity and ensure your right to access your Personal Information. We may need to request other specific information from you to help us process your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also co
   4. Request correction of your Personal Information. You have the right to request us to correct or delete your Personal Information which we have in our possession, where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully.
   5. Request destruction or deletion of your Personal Information. You have the right to ask us to delete or remove your Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have Processed your information unlawfully or where we are required to erase your Personal Information to comply with the law. Note, however, that we may not always be able to comply with your request of destruction or deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
   6. Object to Processing of your Personal Information. You have the right to object to our Processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to Processing on this ground. You also have the right to object where we are Processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to Process your information which override your right to object to Processing.
   7. Request restriction of Processing your Personal Information. This enables you to ask us to suspend the Processing of your Personal Information in the following scenarios: - if you want us to establish the information’s accuracy;
      - where we no longer need the information for the purpose for which the information was initially collected but we need it for purposes of proof;
      - where our use of the information is unlawful but you do not want us to erase it;
      - if you want us to transmit your Personal Information into another automated processing system.
      
   8. Withdraw consent. You have the right to withdraw your consent at any time where we are relying on consent to Process your Personal Information. However, this will not affect the lawfulness of any Processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
   9. Submit a complaint to the relevant Data Protection Authority. You have the right to submit a complaint to the Data Protection Authority regarding an alleged interference with the protection of your Personal Information.
   10. Institute civil proceedings. You have the right to institute civil proceedings regarding an alleged interference with the protection of your Personal Information.

   If you wish to exercise any of the rights set out above, please contact us.

   2. Time limit to respond

   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

10. Glossary
    1. Controller means the entity that decides how and why Personal Information is Processed;
    2. Cookie means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
    3. Data Protection Authority means the regulatory authority in the relevant Processing Region responsible for monitoring and enforcing compliance with applicable Data Protection Laws;
    4. Data Protection Laws means all laws and regulations of the relevant Processing Region which are applicable to our Processing of your Personal Information, and where applicable includes Qatar law No. (13) of 2016 Concerning Personal Data Protection and Bahrain law No. 30 of 2018, and POPI and its regulations;
    5. Personal Information means information about an individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual; and where applicable, information relating to an identifiable, existing juristic person; and also has the meaning given to an equivalent term under other applicable Data Protection Laws;
    6. POPI means the Protection of Personal Information Act 4 of 2013;
    7. Privacy Officer means the person responsible for ensuring Sony’s compliance with applicable Data Protection Laws;
    8. Process means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including:
       i) the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
       ii) dissemination by means of transmission, distribution or making available in any other form; or
       iii) merging, linking, as well as restriction, degradation, erasure or destruction of information,
       and Processed and Processing have corresponding meanings, and also has the meaning given to an equivalent term under other applicable Data Protection Laws;
    9. Processing Region means the country whose Data Protection Laws are applicable to our Processing of your Personal Information;
    10. Special Personal Information means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under applicable Data Protection Laws.