Last Updated: 8th February 2023
What Does This Policy Cover?
This policy describes Sony DADC Europe GmbH and its affiliates’ use of your data. References in this policy to “DADC,” “we” or “us” shall mean Sony DADC Europe GmbH.
Please note that when you enter any sub-sites accessible through DADC Properties, such sub-sites may have their own specific privacy policies. Additionally, the properties of affiliated DADC companies, including some that are linked to/from the DADC Properties, may have different policies; therefore, please review the privacy policies on those properties if you visit them.
What Information Do We Ask You to Provide Us?
With the exception of information related to establishing an account and login credentials for any of the DADC Properties, DADC does not generally require that you provide us with personal data in order to visit and use the DADC Properties.
Therefore, the information that we collect from you and process may include:
- First name, last name, company name, and title
- Your log-in credentials for any of the DADC Properties
- Contact information, such as email address, mailing address and phone number
- Your preferences, including any consents you have given us
What Information Do We Collect from You Automatically?
In addition to any personal data or other information that you choose to provide to us via the DADC Properties, whenever you visit or interact with the DADC Properties, DADC may automatically collect 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 DADC Properties and any referring property. (A Device Identifier is a number that is automatically assigned to your Device when you access a website, mobile app or other digital property or its servers. The DADC Properties identify your Device by its Device Identifier).
DADC may also automatically collect information about your Device, such as the platform, operating system, or browser type for the Device you use to access the DADC Properties and any referring property.
In addition, DADC, as well as certain analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the DADC Properties (“Usage Information”). Usage Information may include, in part, browser type, operating system, IP address, the content served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views.
Therefore, the information that we may automatically collect from you and process may include:
- Your IP address or another unique identifier, such as a Device Identifier
- Information related to your Device such as the platform, operating system, browser type, or physical location
- Your Usage Information such as the content served, the time at which the content was accessed and/or the time spent using the content, and the preceding content views
How Do We Use This Information, and What Is the Legal Basis for This Use?
We process this personal data for the following purposes:
- As required for business purposes or to establish and fulfill a contract with you. This may include verifying your identity, communicating with you and providing services relevant to our business.
- As required by DADC to enable our business and pursue our legitimate interests, in particular:
- we will use your information to provide services you have requested, and respond to any comments or complaints you may send us
- we monitor use of the DADC Properties, and may use your information to help us monitor, improve and protect our content, services and the DADC Properties, both online and offline
- we may use information you provide to tailor your experience on the DADC Properties or personalize our services for you
- to provide you with information about offerings that may be of interest to you
- to provide you with support and answer questions or other requests
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law
- we may use information you provide to investigate any complaints received from you or from others, about the DADC Properties or our services
- we may also use the information we collect to improve the DADC Properties and our content and services, for internal business purposes, and to contact you with regard to your use of the DADC Properties and, in our discretion, changes to any of our policies
- Compliance with applicable laws and protection of DADC’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, and investigative purposes (including disclosure of such information in connection with legal process or litigation).
- With your permission, after we have asked for and obtained it, in connection with a new purpose not otherwise described in this policy.
In addition, we may send you direct marketing in relation to our services, or other services provided by our affiliates and carefully selected partners. You will be able to opt-out of those materials by following the instructions in the communication.
Who Will We Disclose This Information to, and Where?
To Affiliates, Other DADC Companies, and Other Entities
DADC may disclose your personal data with companies affiliated with DADC, including other companies in the Sony Group of companies (“Affiliates”), so that those Affiliates can (i) assist us with fulfilling your requests or improving our content, services or advertising; and/or (ii) contact you about other content, services or other offerings that may be of interest to you.
We may from time to time employ other entities to perform functions on our behalf, and thus, we may also disclose your personal data with these service providers to assist us with providing content, fulfilling your requests, improving our content, services or advertising, or otherwise performing services for DADC. As one example, if you access content or services that are published, developed or supported by an Affiliate or other entity, your personal data may be disclosed with that Affiliate or other entity for purposes related to that content or those services, including service administration and/or development. Additionally, we may disclose your information in order to host or operate the DADC Properties, for data analysis purposes.
When You Consent or Otherwise Request That We Disclose Your Information
We may offer you the opportunity to consent to the disclosing of your information with other entities, for example so you are able to receive information and/or marketing offers from them. Additionally, you may request, sometimes through your use of an interactive feature or application, that we disclose personal data about you with another entity, and we will typically do so in those circumstances. If you consent or request to receive communications from other entities, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.
We may disclose your personal data with Affiliates for internal reasons, primarily for business and operational purposes, including any corporate reorganization, restructuring or other corporate change. In addition, DADC or any of its assets, including the DADC Properties, may be sold, or other transactions may occur in which your personal data is one of the key business assets in the transaction. In such a case, your personal data may be one of the business assets we transfer. Hence, DADC reserves the right to disclose and transfer user information, including personal data, in connection with any activity and/or transaction described above.
Legal Protections and Law Enforcement
We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifier (including IP address)), to other entities: (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 other entities, visitors to the DADC Properties 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. Such disclosures may be carried out without notice to you.
Cookies & Other Web Tracking Technologies
DADC uses commercially reasonable safeguards to help protect and secure your personal data, and we use reasonable efforts to obtain the agreement of our Affiliates and service providers to take steps to protect the confidentiality, security, and integrity of personal data we disclose to them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid ‘phishing’ schemes, where someone may send you an e-mail that looks like it is from DADC asking for your personal data. You understand that any message or information you send to a DADC Property may be read or intercepted by others. DADC does not ensure or warrant the security of any information you transmit to us, and you use the DADC Properties and provide us with your information at your own risk.
How Do We Treat Children’s Personal Information?
The DADC Properties are open to all individuals. We do not knowingly collect or permit the collection, storage or use of any personal data from anyone under 16 years of age. If you are a parent or guardian who knows or has discovered that your child under the age of 16 has submitted his or her personal data or other information without your consent, permission or authorization, please contact us immediately.
For Residents of the United States
If you are a parent or guardian who knows or has discovered that your child under the age of 13 has submitted his or her personal 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, personal data of your child has been collected and how it has been used and/or disclosed; (b) remove your child’s personal 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.
Retention of Personal Information
We will only retain your personal data for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information.
Notice to Residents of the European Economic Area (EEA)
How can you access your personal data and what are your rights?
If you would like a copy of the personal data that we store about you in our customer databases, please contact us using the details given in the “Contact us” section below.
This is in addition to your legal rights, including the right to access a copy of your personal data, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact us” section below.
Where we are processing personal data based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.
You may also have, for some data processed by us, a right to data portability, i.e., the right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.
You can exercise these rights by contacting us using the details given in the “Contact us” section below. You may be asked to provide some proof of identification so that we can verify that it is you making the request.
DADC and our Affiliates may collect, transfer and/or retain your personal data in jurisdictions that do not have the same level of legal protections for personal data as your local jurisdiction. DADC undertakes appropriate and suitable safeguards to ensure your rights continue to be protected. If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.
Notice to California Residents
If you reside in California, we are required to provide additional information to you about how we collect, use and disclose your information, and your rights with regard to your information.
CA Personal Information Collection, Source, Purpose of Use, and Retention. CA Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“CA Personal Information”).
Collection, Use, and Purpose. We collect your name, title, e-mail address, account login information, mailing address, phone number, preference, IP address, other unique identifiers, device information (such as platform, operating system browser type, location, and Usage Information) from you directly or indirectly through your interaction with any system or application. We collect this CA Personal Information in order to provide you the services. We do not collect or process Sensitive Personal information.
Retention. We will keep your CA Personal Information for as long as it is necessary for the relationship with you or the purposes detailed above or necessary to establish or defend legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant CA Personal Information for specific periods.
Selling / Sharing. We do not Sell CA Personal Information or Share CA Personal Information for the purposes of cross-context behavioral advertising.
CA Personal Information Disclosed to Third Parties for Business Purposes
In the preceding twelve (12) months, we may have disclosed your CA Personal Information for Business Purposes to other Sony Affiliates to provide services on our behalf such as: maintaining or servicing accounts, providing IT services, fulfilling orders, receiving payment, and other similar services on our behalf.
California Consumer Rights
Subject to certain exceptions, as a California resident, you may have the following rights to request:
- Access. You can request access to:
- the categories of CA Personal Information we have collected about you;
- the categories of sources from which the CA Personal Information is collected;
- the business or commercial purpose for collecting or sharing CA Personal Information;
- the categories of third parties to whom we disclose the CA Personal Information;
- the specific pieces of CA Personal Information we have collected.
- Correction. You can request correction of the CA Personal Information we maintain about you.
- Nondiscrimination. We will not discriminate against you based solely upon you exercising your rights under CCPA.
Exercising Your California Consumer Rights
If you are a California resident and wish to exercise any of these rights, please: (i) contact us by sending an email to firstname.lastname@example.org. or (ii) write to us at write to us at Sony DADC Europe GmbH, Sonystrasse 4, 5303 Thalgau, Austria. Attn: Privacy Office. When submitting your request, you must indicate the specific nature of your request, referencing “Your California Privacy Rights,” and include your first and last name, mailing address, zip code and email address.
When exercising your rights as described above, you may be asked to provide additional proof of identification so that we can verify your identity and validate the request. We are not responsible for requests that are not labeled or sent properly, or do not contain sufficient information to allow us to process your request.
Agents. If you are an authorized representative submitting a request on a resident’s behalf, please complete the applicable request per the instructions above. 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. In either case, please also indicate in your e-mail the nature of your request. The resident’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the resident to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the resident’s behalf, we may deny the request.