Last Updated: [2024-12-23]
This Privacy Policy sets out how Sony Group Corporation, of 1-7-1 Konan, Minato-ku, Tokyo, Japan (“Sony”, “we”, “our” or “us”) collects, uses, stores and otherwise processes Collected Data (defined below) in relation to Easy Predictive Analytics, a predictive analytics tool that operates on a browser (“Easy Predictive Analytics”).
It also describes your data protection rights, including the right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 “Privacy Rights” below.
Please note that Easy Predictive Analytics is intended for business use only. Easy Predictive Analytics is not intended for purchase by residents of the State of California or for use in the State of California. Your use of the Easy Predictive Analytics is governed by the Terms & Conditions.
1.1 “Collected Data” has the meaning set forth in Section 2 below.
1.2 “Sony Group Company” means Sony and 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).
1.3 “Service Provider” means any third party who processes personal data on behalf of Sony, including but not limited to hosting providers, analytics service providers and customer support providers.
Sony collects data as described below, which may include personal data, (collectively, the “Collected Data”) directly from you or indirectly through other Sony Group Companies and/or third parties, if any. For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of “Controller” and “Processor” are defined, Sony is the “Controller” of the Collected Data.
Notwithstanding the foregoing, the Collected Data does not include data which is or has been fully anonymized, including personal data which has been rendered anonymous in accordance with legal requirements such that it is incapable of being linked back to or associated with an individual. Sony commits to maintaining anonymized data as such and may use such anonymous data without restriction.
2.1 Data collected directly from you
2.2 Data collected indirectly from other Sony Group Companies and/or third parties
3.1 Sony processes your Collected Data for the purposes as described below. For these purposes, Sony may use Collected Data in conjunction with the information collected through other Sony Group Companies’ products and services if you use one of those.
| Purpose | Category of Collected Data |
|---|---|
|
Provision of Easy Predictive Analytics To provide Easy Predictive Analytics to you. This includes making necessary notifications and providing updates. |
Collected Data listed in Section 2.1-2.2 |
|
Enhancement of our products, services and business To analyze your Collected Data in order to improve and develop Sony Group Companies’ products, services and business. |
Collected Data listed in Section 2.1-2.2 |
|
Marketing and advertising To process your information so that we will be able to deliver other marketing and targeted advertising to you via our advertising partners. |
Collected Data listed in Section 2.1 |
|
Protecting the interests of Sony Group Companies and users To protect Sony Group Companies’ business interests and legal rights and the interests and legal rights of our users. 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 proceedings or litigation). |
Collected Data listed in Section 2.1-2.2 |
|
Compliance with law To respond to requests from and, where required, report content to government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws. |
Collected Data listed in Section 2.1-2.2 |
Please note that Sony processes the User Contents solely for the purpose to operate and provide Easy Predictive Analytics.
3.2 Where we collect the Collected Data to perform a contract with you, or where we have to collect Collected Data by law, provision of this data is mandatory, and we will not be able to carry out Easy Predictive Analytics without this information. In all other cases, provision of any requested Collected Data is optional, but not providing information may affect your ability to use the services or use particular aspects of the services if information is needed for those purposes.
Sony shares your Collected Data with the following entities.
| Entities with whom we share Collected Data | Detail |
|---|---|
| Sony Group Companies |
We share Collected Data with Sony Group Companies where those companies process it on our behalf to provide products and services to you. If we have your permission, we also share Collected Data under the following categories with Sony Group Companies. for them to send you marketing materials or survey requests. ＜Categories of Collected Data＞ [2.1-2.2] |
| Service Providers |
We share Collected Data under the following categories with Service Providers, including Sony Group Companies. ＜Categories of Collected Data＞ [2.1-2.2] |
| Government authorities, law enforcement officials, regulators, and court and similar |
We may share some or all Collected Data under the following categories with government authorities and/or law enforcement officials if required by law, or if necessary for us to protect our legitimate interests, or the interests of others, in compliance with applicable laws. ＜Categories of Collected Data＞ [2.1-2.2] |
| Counterparty of Business transfer |
In the event that we undertake a merger, acquisition, reorganization or disposal, some or all Collected Data under the following categories may be disclosed to any prospective purchaser and/or its advisers and will be passed to the new owners of the business. ＜Categories of Collected Data＞ [2.1-2.2] |
| Professional advisors |
In some cases, if this is necessary for the purposes listed above, we may share some or all Collected Data under the following categories with professional advisers including lawyers, auditors, or insurers. ＜Categories of Collected Data＞ [2.1-2.2] |
We will process, store and transfer Collected Data for the purposes outlined in this Privacy Policy from your country/regions of residence globally to countries/regions outside your country/region of residence. Collected Data will be processed by staff operating outside your country/region of residence who work for us or for one of our Service Providers. Some of the countries and regions may not provide the same level of data protection as your country.
6.1 Sony will keep the Collected Data for as long as it is necessary for the relationship with you and the purposes detailed in Section 2 or otherwise permitted or required under applicable law.
6.2 Sony may retain Collected Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Collected Data for specific periods.
We protect the Collected Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized collection, use, access, disclosure, disposal and alteration of Collected Data, and the loss of any storage medium or device on which Collected Data is stored in accordance with common Sony Group policies based on industry standards and best practices such as the International Organization for Standardization (ISO) 27001 series of standards and best practices such as the National Institute of Standards and Technology (NIST) SP800 series. These measures include systematic implementation and periodic review of information security management, periodic employee education and training, periodic inventory of information assets, implementation of physical security measures (Management of employee entry and exit, terminal management, etc.), encryption of communications, access controls, and periodic vulnerability management of information systems.
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of Collected Data concerning children. We do not directly or knowingly collect Collected Data from children. 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 Collected Data without your consent, you should contact us as indicated in Section 10 “Contact Information” below.
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.
The data controller for Collected Data is Sony Group Corporation, of 1-7-1 Konan, Minato-ku, Tokyo, Japan. Please contact us here if you have any questions or concerns about this privacy policy or if you wish to exercise any legal right you have regarding Collected Data.
In some jurisdictions, you have certain rights with respect to the Collected Data that Sony holds about you. These may include the right to request access to the Collected Data and/or you may request that Sony corrects, amends, deletes, erases, destroys, blocks/restrict processing and/or use of such Collected Data. You may also object to Sony’s processing of Collected Data. These rights may be limited, for example if fulfilling your request would reveal personal 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 rights available to you, please contact us as described in Section 10 “Contact Information”. You can also contact us at: sgc-contact-easy-predictive-analytics@sony.com
Notice to Residents of U.S. States (excluding CA)
We set forth 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.
Consumers in certain states with comprehensive privacy laws may have the following rights:
If you would like to submit a request to exercise one of the rights listed above, you can do so as described in Section 10 “Contact Information”.
