Other websites or
properties of Sony Group Companies including some that are linked to/from the
Website, may have different privacy policies; and some of the subpages of this
Website may have additional privacy notices to cover activity not covered by
this Privacy Policy: therefore, please review the privacy policy or privacy
notices on those websites or properties if you visit them.
This Privacy Policy
explains the types of information that we may collect and hold, how that
information is used and with whom the information is shared. It also sets out
how you can contact us if you have any queries or concerns about this
information.
Data protection laws
and regulations in certain jurisdictions defines the concepts of
"controller" and "processor". Unless we specifically state
otherwise, Sony is the "controller" of the Collected Data described
in this Privacy Policy.
"Sony Group
Companies" shall mean any legal entities controlled by Sony (the term
"control" in this context means the direct or indirect ownership of at
least fifty percent (50%) of the voting interest in such corporation or the
power in fact to control the management decisions of such entity).
1.
What personal information we collect
Sony collects data as
described below which may include personal information (collectively, the
"Collected Data") related to your use of the Website.
Information
we collect automatically about your devices you use to access the Website
Sony may automatically collect
your IP address or other unique identifiers for the computer, mobile device, or
other device you use to access to the Website.
Information
related to contact and support interactions with us
When you contact Sony for
business inquiries about Genie Promotion, as well as to obtain product or
service support, we may collect your personal information, such as name, email
address, your company name, etc.
2. Why
we process personal information
The purposes for which
we use Collected Data, and the legal bases for such processing, are as follows:
(i)
To provide the functionality of the Website to you
Sony
may processes Collected Data in order to provide the functionality of the Website,
this includes authenticating your access to the Website (including applications
thereon), responding to your inquiries and fulfilling your requests, such as
sending you documents or email notifications that you have requested, and
sending you important information about Genie, changes to our terms,
conditions, and policies, and/or other administrative information. The
legal basis for the processing above is the legitimate interest of Sony.
(ii) To improve and
develop products and services
Sony may process
Collected Data to improve the functionality and user experience of the Website
(including applications thereon). The information may also be used to develop
new websites and applications by helping us understand the way you use them, so
that we can provide improved user experiences today and/or in the future. The
legal basis for the processing above is the legitimate interest of Sony.
(iii) To protect the
interests of Sony Group Companies and website visitors
Sony may process
Collected Data to protect the Sony Group Companies, their business interests
and legal rights and website visitors. This includes the use of Collected Data
in connection with legal claims, compliance, regulatory, auditing,
investigative purposes (including disclosure of such information in connection
with legal process or litigation). The legal basis for the processing above is
the legitimate interest of Sony.
(iv) To manage security
or technical issues
Sony may process
Collected Data to detect, prevent, address and analyze
security or technical issues in relation to the Website (include application
thereon). The legal basis for the processing above is the legitimate interest
of Sony.
(v) To comply with law
Sony
may process Collected Data to comply with applicable law and regulations, this
includes responding to requests from government or public authorities, law
enforcement officials, courts, regulators or similar in accordance with our
legal and regulatory obligations under applicable laws.
The
legal basis for the above is that the processing is necessary for compliance
with a legal obligation.
3. How
we share your personal information
We may share Collected
Data with third parties as follows:
(i)
Sony Group Companies
We may share Collected
Data with Sony Group Companies to the extent such sharing of data is necessary
to fulfil a request you have submitted and/or for customer support, technical
operations, account management purposes.
(ii) Third-party contractors
We may share Collected
Data with third-party contractors who provide services such as IT and system
administration and hosting, research and analytics, moderation and safety
assistance, customer support for the purposes described in Section 2 above.
(iii) Business transfer
In the
event that we undertake a merger, acquisition,
reorganization or disposal, Collected Data may be transferred to the purchasing
or acquiring entity as part of the transaction.
(iv) Government
authorities, law enforcement officials, regulators, courts and similar
We may share Collected
Data with government authorities, law enforcement officials, regulators, courts
and similar for the purposes described in Section 2 above.
(v) Professional
advisers
In individual instances,
we may share Collected Data with professional advisers including lawyers,
bankers, auditors, and insurers who provide consultancy, banking, legal,
insurance and accounting services.
Since we operate as
part of a global business, the recipients referred to above may be located
outside the jurisdiction in which you are located. See the Section 5 " below for more information.
4. How
long we retain your personal information
We retain Collected
Data for as long as we continue to make the Website available to visitors, and
for a further 6 months following discontinuation, at which point the
information will either be anonymized or destroyed. Please note that we may be required
to retain certain information by law.
5. International transfers of personal information
Collected Data may be
processed, stored and transferred for the purposes
outlined in this Privacy Policy from your country to countries which may not be
regarded as providing the same level of data protection as your country.
We will put in place
appropriate safeguards (such as contractual commitments) to ensure that Collected
Data is adequately protected and transfers of Collected
Data meet the requirements of any applicable data protection legislation such
as the EU standard contractual clauses. For more information on the appropriate
safeguards in place, please contact us as described in Section 10 "Contact
Information" below.
6.
Security
Sony undertakes
reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive
to protect Collected Data, we cannot guarantee or warrant the security of any
information transmitted to us through your use of the Website or that we store
on our systems or that is stored on our third-party contractors' systems.
7. Our
policy regarding children
Sony is committed to
complying with all applicable laws and regulations regarding the collection,
storage and use of personal information concerning children. The Website is not
directed to and does not knowingly collect personal information from children
under the age of 18. Depending on your country/region of residence, this
threshold age for a child may differ. If you are a parent or guardian and are
concerned that your child has provided us with personal information without
your consent, you should contact us as indicated in Section 10 "Contact
Information" below.
8.
Privacy rights
In some countries, you have
certain rights with respect to the Collected Data Sony processes about you.
These may include the right to request a copy of the Collected Data that Sony
holds about you and/or you may request that Sony corrects, deletes,
blocks/restricts processing of such Collected Data. You may also object to
Sony's processing of Collected Data. In some countries, you may also ask us to
provide your Collected Data to you in a structured, machine-readable format and
ask us to share (port) such data with another organisation.
These rights may be limited, for example, if fulfilling your request would
reveal Collected Data about another person, or if you ask us to delete
Information which we are required by law to keep or have compelling legitimate
interests in keeping. If you would like to exercise any of these rights, please
contact us as described in Section 10 "Contact Information" below.
If you are not
satisfied with how we have handled your questions, concerns or have any
complaints about how we process Collected Data, you have a right to lodge a
complaint with your national or any other data protection supervisory
authority.
Where we collect
Collected Data to administer our contract with, this is mandatory
and we will not be able to provide services to you without this information. In
all other cases, provision of the requested Collected Data is optional, but
this may affect your ability to use the services or use particular
aspects of the services where the information is needed for those
purposes.
9. Changes
to this Privacy Policy
This Privacy Policy may
be updated from time to time for any reason. We will notify or request your
consent (if necessary under applicable law) of any
changes to this Privacy Policy.
10.
Contact information
If you have any questions
or concerns about this Privacy Policy, or if you wish to exercise any legal
right you may have in respect of your personal information, please contact inquiry(at)genie-project.net. (*Replace (at) with @)
11.
ADDITIONAL NOTICES - US STATE RIGHTS
Notice to Virginia
Residents:
We set forth above in
our Privacy Policy the categories of personal data we process, the purpose for
processing personal data, the categories of personal data shared, and the
categories of third parties with whom personal data is shared.
Virginia Consumers have
the following rights with respect to their personal data subject to the
meanings and exceptions set forth in the Virginia Consumer Data Protection Act
("VCDPA"):
1) To
confirm whether we are processing your personal data defined in the VCDPA
(hereunder, "Personal Data") and request to access such data.
2) That
we correct inaccurate Personal Data we hold about you.
3) That
we delete the Personal Data provided by you or obtained about you.
4) To
obtain a copy of the Personal Data previously provided by you to us and, to the
extent feasible, in a readily usable format to allow data portability.
If you are a Virginia
Consumer and would like to exercise any of these rights, please complete the
form here: Data Requests .
Opt-out of Targeted
Advertising: Virginia Consumers have the right to opt-out out of the processing
of your Personal Data for the purposes of targeted advertising. Sony engages in
online advertising and analytics practices that may be considered
"targeted advertising" under the VCDPA. To exercise your rights to
opt-out of targeted advertising, you may submit a request here: Opt-out of
Targeted Advertising .
In addition, you may
need to disable sharing through cookies set by 3rd parties on certain Sony
websites which may be considered targeted advertising under the VCDPA. To
manage your cookie preferences, please refer to the
"Manage
Cookies" link on the cookie banner or in the footer for the applicable
website and ensure that "Targeting Cookies" are disabled.
While the VCDPA also
permits you to opt-out of the sale of your Personal Data, at
this time we do not engage in the sale of Personal Data to third parties
for monetary compensation. Similarly, we do not process your Personal Data for
purposes of profiling as set forth in the VCDPA that would require such an
opt-out.
VCDPA
Appeals
Pursuant to the VCDPA,
if, for any reason, you would like to appeal a decision made by us relating to
your request, you have the right to submit an appeal and can do so by
completing this form: Data Requests . Please include
your full name, the basis for your appeal, and any additional information to
consider.
Notice
to California Residents
This California Privacy
Notice is effective as of [Date].
This California Privacy
Notice supplements our Privacy Policy and applies only to California residents.
This notice sets forth the disclosures and rights for California Consumers
regarding their personal information, as required by the California Privacy
Rights Act and any implementing regulations adopted thereunder
("CPRA"). Terms (including defined capitalized terms) used in this California
Privacy Notice have the same meanings given in the CPRA, unless otherwise
defined.
California
Consumer Rights. Subject to certain exceptions, as a
California consumer, you may have the following rights regarding your CA
Personal Information:
- Request
to Know. Request information regarding what Personal Information we collect,
use, disclose, and sell, including the right to request that we provide you
with the categories and/or specific pieces of Personal Information we have
collected about you;
- Request
to Delete. Request deletion of the Personal Information we collect about you;
- Request
to Correct. Request correction of inaccurate Personal Information that we
maintain about you;
- “Do
Not Sell or Share My Personal Information.” Request to opt-out of the “sale” of
your Personal Information or the “sharing” of your Personal Information to a
third party for cross-contextual behavioral advertising (i.e., targeted
advertising). As we do not knowingly collect Personal Information of residents
younger than the age of 16, we also do not knowingly sell or share for
cross-contextual behavioral advertising their Personal Information.
"Limit the Use and
Disclosure of Sensitive Personal Information." Under the CPRA, we must
only provide the Right to Limit the Use and Disclosure of Sensitive Personal
Information when Sensitive Personal Information is collected or processed for
the purpose of inferring characteristics about a consumer or does not fall
under certain statutory exceptions. Sony's use and disclosure of Sensitive
Personal Information is not used for such purposes and/or falls within the
statutory exceptions, and we therefore do not offer this right at this time.
Verifying
Requests. In your request, you must provide enough
information to allow us to verify you are the person about whom we collected
Personal Information, or their authorized representative. You must also
describe your request with enough detail so that we can understand, evaluate and respond to it. We can't respond to your request
if we can't verify your identity. Making such a request does not require you to
create an account with us, and we will only use the information you provide in
a request to verify your identity.
We will take reasonable
steps to verify your identity based upon the information you provide and the
type of request you are making. When you exercise your Right to Know, Right to
Delete, and/or Right to Correct, we may ask that you provide us with additional
information in order to verify your identity and
fulfill your request. If we are unable to verify that the individual submitting
the request is the same individual about whom we have collected information (or
someone authorized by that individual to act on their behalf), we will not be
able to process the request.
Pursuant to the CPRA,
we will not require you to verify your identity, beyond asking for the
information necessary to complete your request, when
you exercise your Right to Opt-Out of Sale or Sharing.
Agents.
If you are an authorized representative submitting a request on a consumer's
behalf, please complete the applicable fields of information in the submission
form. We will follow up to request a signed, written permission signed by the
individual who is the subject of the request authorizing you to make the
request on their behalf. The written permission must state your full legal
name, the full legal name of the individual who is the subject of the request,
and a clear description of the permission granted. Alternatively, you may
submit a copy of a power of attorney under Probate Code sections 4000-4465. The
consumer's identity, in addition to your own, will need to be independently
verified in order for us to be able to fulfill your
request. Please keep in mind that if we do not receive adequate proof that you
are authorized to act on the consumer's behalf, we may deny the request.
Exercising
your Rights
Right to Know; Right to
Delete; Right to Correct
If you are a California
Consumer and would like to exercise your Right to Know, Right to Delete, and/or
Right to Correct, please submit your request at: Data Requests; or you may call
us toll-free at 1-833-681-9900.
For requests to know, in order to have us provide specific pieces of information,
we will require a signed declaration under penalty of perjury that you are the
consumer whose Personal Information is the subject of the request.
Do Not
Sell or Share for Cross Context Behavioral Advertising
Right
to Opt-Out of Sale/Sharing
California Consumers
have the right to opt-out of the sharing of your Personal Information to a
third party for cross-context behavioral advertising (i.e., targeted
advertising). California Consumers also have the right to opt-out of the
"sale" of your Personal Information for monetary or other valuable
consideration. Please note that we do not sell Personal Information for
monetary or other valuable consideration. If you are a California Consumer and
would like exercise your Right to Opt-Out of Sale or
Sharing, please submit your request at: Do Not Sell or Share My Personal Information.
Cookie
Based Opt-Outs for Do Not Sell or Share for Cross Context Behavioral
Advertising
Sony engages in online
advertising practices (and certain analytics or similar activities), which may
be considered a “sale” or “share” for cross-context behavioral advertising as
defined in the CPRA. In addition to submitting the form above, you may need to
disable sharing through cookies set by 3rd parties on certain Sony websites. To
manage your cookie preferences, please refer to the “Manage Cookies” link in
the cookie banner or footer for the applicable website and ensure that
“Targeting Cookies” are disabled
Data
Retention
We retain all
categories of Personal Information described in this California Privacy Notice
for as long as it is reasonably necessary for the purposes outlined in this
California Privacy Notice, considering the time period reasonably necessary to:
provide the goods or services you request; exercise the choices and rights you
have requested; comply with our contractual obligations; comply with applicable
legal, regulatory, or other obligations; including litigation holds and agency
regulations. Except as noted differently specific pages or apps, we retain your
personal information while you have an account with us, or while you are using
the Website or continuing to interact with us.
Right
to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
California Consumers
have the right to not receive discriminatory treatment for exercising CPRA
rights. We will not discriminate against you for exercising your CPRA rights.
Notice
of Financial Incentive
Under California
regulations, if we offer certain loyalty or similar program(s) directly or
reasonably related to the collection, retention or deletion of your Personal
Information, such program may be considered a "financial incentive",
In such case, we will be required to make additional disclosures to you, which
we will provide when you agree to participate
Personal
Information We Collect & Purposes for Collection
The Personal
Information we collect about you will depend upon how you use the Website or
otherwise interact with us. Accordingly, we may not collect all
of the below information about you. In addition to the below, we may
collect and/or use additional types of information and will do so after
providing notice to you and obtaining your consent to the extent such notice
and consent is required by the CPRA.
We may have
used Personal Information for the following business or commercial purposes:
|
Categories
of Personal Information Collected |
Business
or Commercial Purposes for Collection of Personal Information |
Categories
of Sources from Which Personal Information Was Collected |
Categories
of Third Parties to Whom We May Disclose Personal Information for a Business
Purpose |
Categories
of Third Parties to Whom this Type of Personal Information is Sold or Shared
for Cross Context Behavioral Advertising |
|
Identifiers Such as name, phone number, mailing address,
email, and online or device identifiers such IP address |
We may use this type of information to: Provide requested services; respond to your
inquiries; personalize your experience on our websites and online; monitor
and maintain security of our systems and prevent fraud; internal business,
legal and compliance purposes |
We may collect this type of information from: Consumers; Sony Group companies; Third-Party
Business Partners; Cookies and Tracking Technologies |
We may disclose this type of information to: Sony Group companies; Service Providers; Data
Analytics and Advertising Providers; Business Partner;. |
Third party advertising, analytics, and other
similar marketing business partners may have access to this data, and this
may be considered a "sale" or "share" under the CPRA
under certain circumstances. |
|
Internet or Other Electronic Network Activity This category includes 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. |
To personalize your experience on our
websites and online; serve advertising; monitor and help maintain security of
our systems and prevent fraud; internal business, legal and compliance
purposes |
Consumers; Sony Group companies; Third Party
Applications; Advertising Networks |
Sony Group companies; Service Providers; Data
Analytics and Advertising Providers; Advertising Networks; Legal Authorities
(as required by law); Business Transfer Recipients. |
Third party advertising, analytics, and other
similar marketing business partners may have access to this data, and this
may be considered a "sale" or "share" under the CPRA
under certain circumstances. |
Additional
Notice to California Residents:
If you are a California
resident, under the California "Shine the Light" law, you have the
right to receive: (a) information identifying any third party
companies to which we may have disclosed, within the past year, personal
information pertaining to you and your family for that company's direct
marketing purposes; and (b) a description of the categories of personal
information disclosed. To obtain such information, please email your request to
privacy(at)am.sony.com (*Replace (at) with @), and include your name, email address, mailing address or
zip code, and a reference to "Your California Privacy Rights." We are
not responsible for requests that are not labeled or sent properly, or do not
have complete information.