What does this statement cover?
This statement describes Sony DADC Europe Limited and its affiliates’ use of your data. References in this policy to DADC, we or us shall mean Sony DADC Europe Limited.
This Privacy Statement applies to the information collected by DADC both offline and online, including through www.sonydadc.com and through any interactive features, applications, widgets, blogs, social networks and other online or wireless offerings that post a link to this Privacy Statement, whether accessed via computer, mobile device or other technology (collectively, “DADC Websites”).
What information do we collect?
While DADC does not generally require that you provide us with personal data in order to visit and use the DADC Websites, please note that in order to participate in some activities, we may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as first and last name, e-mail address, mailing address and telephone number). Information may also be collected automatically via your device. DADC may also ask you to provide other information about yourself, which include such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests.
Therefore the information that we collect and process may include:
- your name, username and password;
- your gender;
- your age/date of birth;
- your home address, e-mail address and phone number;
- your marketing preferences, including any consents you have given us;
- information related to the browser or device you use to access the DADC Websites;
- information about how you use the DADC Websites such as the operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding page views;
- 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 both personal data and non-personal data. In the event that a Promotion is offered jointly with a third party, as a result of your participation in such Promotion, your personal data and non-personal 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;
- in addition to any personal data or other information that you choose to provide to us via the DADC Websites, whenever you visit or interact with the DADC Websites, DADC 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 DADC Websites 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.) 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 DADC Websites;
- in addition, DADC, 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 DADC Websites (“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.
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 to establish and fulfill a contract with you, for example if you make a purchase from us or enter a competition we run. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products, prizes or services;
- as required by DADC to enable our business and pursue our legitimate interests, in particular:
- we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of the DADC Websites and online services, and may use your information to help us monitor, improve and protect our products, content, services and DADC Websites, both online and offline;
- we may use information you provide to tailor your experience on the DADC Website or personalize our products or services for you;
- to provide you with information about Promotions or other offerings that may be of interest to you;
- to provide you with support and answer questions or other requests;
- we may use information you provide to investigate any complaints received from you or from others, about our DADC Websites or our products or services;
- we may use your information to invite you to take part in market research;
- we may also use the information we collect to improve the DADC Websites and our products and services, for internal business purposes, and to contact you with regard to your use of the DADC Websites and, in our discretion, changes to any of our policies; and
- 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, investigative purposes (including disclosure of such information in connection with legal process or litigation).
In addition, with your consent, we may send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. Although these will only be sent where you have given your consent, or (where permissible) you have been given an opportunity to opt out, you will be able to opt-out of electronic direct marketing by following the instructions in the communication.
Who will we share this data with, and where?
To Affiliates, Other DADC Companies and Third-Parties
DADC may share your personal data with companies affiliated with DADC (“Affiliates“), so that those Affiliates can (i) assist us with fulfilling your requests or improving our products, content, services or advertising; and/or (ii) contact you about products, content, services or other offerings that may be of interest to you. We may share personal data with: Sony Corporation of America, Sony DADC Europe Limited Austria Branch, Sony DADC Czech Republic s.r.o, Sony DADC Germany GmbH, Sony DADC Iberia S.L, Sony DADC France SAS, OOO Sony DADC, Sony DADC Manufacturing (India) Pvt Limited, Sony DADC Australia Pty Limited, Sony DADC China Co. Limited, Sony DADC Hong Kong Limited, Shanghai Epic Music Entertainment Co. Limited, ENS Entertainment Network Scandinavia Aktiebolag.
To Third-Party Service Providers Providing Services On DADC’s Behalf
We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your personal 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 DADC. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your personal 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 DADC Websites, for data analysis purposes, and for the administration of Promotions.
When You Consent To Have Your Personal Data Shared or Otherwise Request That We Share Your Information
We may offer you the opportunity to consent to the sharing of your information with third parties for example so you are able to receive information and/or marketing offers from third parties. Additionally, you may request, sometimes through your use of an interactive feature or third-party application, that we share personal data about you with a third party, and we will typically do so in those circumstances. If you consent or request to receive communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.
We may share your personal data with other entities affiliated with us 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 Websites, 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 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 DADC Websites 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.
Social Media Applications
Functionality on the DADC Websites may permit interactions between such website 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 DADC Websites 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 DADC Websites.
You may also choose to participate in a third party application or feature (such as one of our Facebook applications or a similar application or feature on a third-party website) through which you allow us to collect and share (or the third party to share) information about you, including personal data. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or if information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party website or interactive service.
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 third-party service providers to take steps to protect the confidentiality, security, and integrity of personal data we share with 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. DADC will never request your personal data through e-mail. You understand that any message or information you send to a DADC Website 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 Websites and provide us with your information at your own risk.
How do we treat children’s personal data?
The DADC Websites 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 personal data from anyone under 16.
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.
Further Information for EEA Individuals
See our fuller Privacy FAQs below for further details on retention periods, international transfers, contact details and the rights of EEA individuals.
What rights do I have in relation to my personal data?
You may be entitled to ask DADC for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at email@example.com.
If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the Information Commissioner’s Office.
Which DADC entity is my data controller, and which affiliates might my data be shared with?
The data controller for your information is Sony DADC Europe Limited, Level 5, 2 More London Riverside, London SE1 2AP, United Kingdom may share your data with the following affiliates listed above.
How long will you hold my data?
Where you are a customer, DADC will keep your information for the length of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. For data about your visits to our websites or applications, DADC will retain this data in accordance with our retention policy. Laws may require DADC to hold certain information for specific periods. In other cases, DADC may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.
Where will you send my data?
Where information is transferred outside the EEA, and where this is to a DADC affiliate or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the Privacy Controller (firstname.lastname@example.org) and/or the Company Secretary (email@example.com).
Publication Date: 08.06.2018 / Version: 1.1