Last Updated and Effective: September 30, 2020
1. Collection of Information
1.1 Information You Provide To Sony
While Sony does not generally require that you provide us with personally identifiable information in order to visit and use the MESH Services, please note that in order to participate in some activities, such as signing up for an account to use our mobile application, or participating in sweepstakes, contests and other promotions (collectively, “Promotions”), we may ask you to provide information that identifies you as a specific individual (such as first and last name, address, e-mail address, mailing address and telephone number). We may also ask you to provide other information about yourself, such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. Some of this information may be considered “personal information” in the jurisdiction where you reside. If you choose not to provide such information to us, you may not be able to participate in certain activities we offer. We may de-identify or aggregate Collected Data, turning it into non-personal Information. This is sometimes accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.
Individuals Younger Than Age 16. (For US residents)
The MESH Services are directed to a general audience. We do not knowingly target or collect any Collected Data from anyone younger than the age of 16, and Sony will delete any Collected Data later determined to be inadvertently collected from a user younger than age 16.
Individuals Younger Than Age 15. (For Japanese residents)
The MESH Services are open to all individuals, though some Promotions may have age restrictions. We do not knowingly collect or permit the collection, storage or use of any Collected Data from anyone younger than age 15. If you are a parent or guardian who knows or has discovered that your child younger than the age of 15 has submitted his or her Collected Data or other information without your consent, permission or authorization, upon request, we will promptly: (a) provide direct notice to you indicating what, if any, Collected Data of your child has been collected and how it has been used and/or disclosed; (b) remove your child’s Collected Data or other information from our database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.
We may offer opportunities to enter into Promotions that we offer, on our own or jointly with a third party. Such Promotions may require registration and the disclosure of Collected Data. In the event that a Promotion is offered jointly with a third party, as a result of your participation in such Promotion, your Collected Data may be shared with such third party, which sharing we will disclose to you at the time you provide your information. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other third parties connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore, always carefully read the rules of the Promotion before entering.
1.2 Information Sony Collects Automatically
In addition to any information that you choose to provide to us via the MESH Services, whenever you visit or interact with the MESH Services, Sony automatically collects certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access the MESH Services and any referring website. (A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) We may directly collect specific location information from your Device if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Services.
In addition, Sony, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the MESH Services (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if Sony associates it with you as a specific and identifiable person, we will treat it as personal information.
1.3 Cookies and Other Tracking Technologies.
The technologies used on the MESH Services to collect Usage Information, including Device Identifiers, may include the technologies described below. You may be able to disable cookies and similar technologies by adjusting your browser settings to disconnect the link between cookie information and non-personal viewing information generated by those technologies.
The methods used to collect Usage Information may include the following:
Cookies & Local Storage. “Cookies” (which may be html files, Flash files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit the MESH Services or otherwise access our online content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Services may make use of this local storage. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies Flash cookies, and other local storage devices may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your MESH Website experience. You may refuse or remove some or all of these cookie and local storage technologies; however, if you choose to do so, some features of our Services may not function properly.
Web Beacons. “Web beacons” (also known as image tags, pixel tags, GIFS or web bugs) are small pieces 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 a number of purposes, including, without limitation, to count visitors to the MESH Services, to monitor how users navigate the MESH Services, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the MESH Services, 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 to the Services, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
2. Uses of the Collected Data
Sony will use the information it collects, including your Collected Data:
to tailor your experience on the MESH Services;
to determine which products and services we offer may be of interest to you;
to allow you to participate in the Services and features offered through the Services
process your registration with the Services, including verifying that your email address is active and valid;
to send you special offers from us, our advertisers, or third-party business partners;
to allow you to participate in the public areas and other features of the Services;
to tailor content, recommendations, and offers we display to you, both on the Services and elsewhere online;
to provide you with information about Promotions or other offerings that may be of interest to you;
to provide you with customer service, support and answer questions or other requests; and
We may also use the information we collect to improve the MESH Services and our products and services, for internal business purposes, to comply with regulatory and legal obligations and to contact you with regard to your use of the MESH Services and, in our discretion, changes to any of our policies.
3. When and With Whom Sony May Share Collected Data
To the extent permitted by law, we may share information, such as aggregate user statistics, demographic information, de-identified information and Usage Information with third parties in our discretion, including for purposes of tailoring promotions, advertising and communications we present to you.
We may also share Collected Data, as specifically disclosed at the time you provide your Collected Data and in the following circumstances:
To Affiliates, Other Sony Companies and Third-Parties.
To Third-Party Service Providers Providing Services On Sony’s Behalf.
We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your Collected Data with third party service providers that assist us with providing content, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Sony. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your Collected Data may be shared with that Affiliate or third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information in order to host or operate the MESH Services, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.
When You Consent To Have the Collected Data Shared or Otherwise Request That We Share Your Information.
We may share Collected Data with our Affiliates for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. In addition, Sony or any of its assets, including the MESH Services, may be sold, or other transactions or transitions may occur whether voluntary or involuntary (such as through bankruptcy) in which the Collected Data is one of the key business assets in the transaction. In such a case, the Collected Data may be one of the business assets we transfer. Hence, Sony reserves the right to disclose and transfer the Collected Data, in connection with any activity and/or transaction described above. By providing your information, you agree that we may transfer such information to the acquiring entity without your further consent.
Legal Protections and Law Enforcement.
We may transfer and disclose information, including the Collected Data, to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms & Conditions or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the MESH Services or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion or as required by law.
4. Advertising, Analytics and Similar Third Party Services and Your Choices
We may partner with third party advertising companies to either display advertising on the MESH Services or to manage our advertising on other sites, and we may use third party analytics service providers to evaluate and provide us with information about the use of the MESH Services and viewing of our content. Ad network providers, advertisers, sponsors, analytics service providers and/or similar third parties may set and access their own cookies, local storage, web beacons and embedded scripts on your device, may collect, set and use unique or non-unique identifiers, and they may otherwise collect or have access to information about you.
We may use a variety of companies to perform advertising and analytics services including:
We utilize first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together to analyze your other information and your interest. If you choose to opt out Google Analytics, please disable Cookies by setting your browser or use Google Analytics Opt-out Browser Add-on.
We utilize Hotjar in order to aggregate data on our website visitors’ behavior using cookies. Please note that Hotjar does not collect any personal information in its cookies. Examples of the type of information collected include, but is not limited to, pages visited, interaction on pages, device and browser type, and the geographic location.
Some of our service providers may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may wish to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an opt-out for participating companies.
"Do Not Track" Signals- Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Services do not currently interpret, respond to or alter their practices when they receive Do Not Track signals. Please note that third parties may collect personal information about your online activities over time and across different websites when you visit our website or other online websites and services. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
For mobile apps, you can typically limit ad tracking using the settings on your phone, tablet or other mobile device.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.
5. Social Media Interactions
Functionality on the MESH Services may permit interactions between such MESH Services and a third-party website, such as enabling you to “like” a product or “share” content to third-party websites. If you choose to “like” or “share” content or to otherwise post information from or via the MESH Services to a third-party website, feature or application, that information may become public and the third-party web site may have access to information about you and your use of the MESH Services.
6. Links To and Sony Content On Other Websites
The MESH Services may contain links to other websites that are operated and controlled by third parties that we do not control. This includes links of advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. In addition, Mesh or other Sony content may be included on web pages and other online services that are not associated with us and over which we have no control and which may send their own cookies to your Device and independently collect data or solicit personal information. A link from any MESH Service to any other online content does not mean that Sony approves of, endorses, or recommends it. Sony is not responsible for the privacy practices of any third party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content it does not own and control.
7. Notice to California Residents If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.
Identifiers: such as email address, username and password for MESH Services;
Commercial Information: such as product types or applications purchased or obtained, transaction information or similar information;
Internet or other electronic network activity information: such as computer and connection information, browser type, operating system, page views, traffic to and from the websites, advertising data and other standard weblog information collected via cookies, web beacons, and related tracking technologies.
Sources of CA Personal Information. We may collect CA Personal Information from the following sources:
- o Directly from Consumers: such as when you voluntarily provide CA Personal Information when purchasing products or services or registering on our Services, or automatically from your device;
- o Third-Party Applications: such as blogs or chat rooms, or social networks;
CA Personal Information Disclosed For Business Purposes.
- o Sharing your CA Personal Information for Business Purposes: In the preceding twelve months, we may have shared the following categories of CA Personal Information for business purposes: Identifiers, Commercial Information, Internet or other electronic network activity information. This information may be shared for the purpose of providing services to you, for legal compliance, or to protect legitimate interests, in compliance with law.
- o Sale of CA Personal Information: In the preceding twelve months, we have not sold (as defined under CCPA) CA Personal Information.
California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information: (i) Access. Request access to your CA Personal Information that we collect, use, or disclose; (ii) Deletion. Request deletion of your CA Personal Information; provided that to the extent permitted by applicable law, we may be required to retain some of your CA Personal Information; and (iii) CA Personal Information Disclosed For Business Purposes. Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months.
Authorized Agents: To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.
Access Notice in Alternative Formats. Consumers who need assistance accessing the notice in alternative format can do so by emailing us at: firstname.lastname@example.org
Sony uses commercially reasonable safeguards to help protect and secure the Collected Data, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of Collected Data we share with them. However, no electronic or wireless data transmission or electronic storage of information can be guaranteed to be 100% secure. Sony does not ensure or warrant the security of any information we collect, and you use the MESH Services and provide us with your information at your own risk.
9. Consent to Processing
The MESH Services are operated in Japan. If you are located in the United States, the European Union, Canada or elsewhere outside of Japan, please be aware that Collected Data will be transferred to and processed in Japan. By using the MESH Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of Collected Data in Japan, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.