PRIVACY POLICY FOR “REON POCKET” APPLICATION

Last Updated and Effective Date: 4/1/2021

This Privacy Policy applies to “REON POCKET” application (the “Application”). The Application is a mobile application dedicated to REON POCKET devices from SONY, and it allows you to set the temperature of your REON POCKET device according to your preference.

In this Privacy Policy, we use “SONY,” "we," "us," "our" and “ourselves” to refer to Sony Group Corporation. “SONY Affiliates” shall mean Sony Group Corporation, which is the ultimate parent company of Sony group companies and any legal entities controlled by Sony Group Corporation. SONY and SONY Affiliates shall be collectively referred to as “SONY Group”. 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. SUMMARY OF KEY POINTS

We use the Collected Data (defined below) to provide you with features and functions of the Application, and to provide you with other requested content related to our services and other offerings. We also use the Collected Data to improve and develop SONY Group’s current and future products and services. Please read here to learn more.

This Privacy Policy also describes your data protection rights, including a right to object to some of the processing which SONY carries out. Please read here to learn more about your rights.

We disclose the Collected Data when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Please read here to learn more.

Depending on where you are located, the Collected Data may be transferred out of your home country/region to the United States of America, Japan and other jurisdictions that may not provide the same level of data protection as your home country/region. Please read here to learn more.

2. WHAT INFORMATION DO WE OBTAIN?

We collect and use information or data as described below, some of which may be considered personal information under applicable law in your jurisdiction (collectively, the “Collected Data”), in relation to your use of the Application.

(i) Information you provide to us:

We collect information that you provide to us, such as
- Age (per 10 years old);
- Height (per 5cm);
- Weight (per 5kg);
- Place of Residence (per state); and
- Sex.

(ii) Information we collect automatically:

We automatically collect information about your use of the Application, such as:
- Information about your REON POCKET device (e.g., serial number, internal temperature, usage status (stationary / walking, etc.), operation status, settings, and system status (power status, etc.);
- Information about your smartphone: IP address, OS and its version, locale and time zone of OS settings, and device information (model, display size, etc.); and
- Information about the Application: Universally Unique Identifier, version of the Application, operation status and settings.

3. HOW DOES SONY USE THE COLLECTED DATA?

We use the Collected Data for the following purposes unless they are anonymized so that they no longer identify you. We use such anonymized data without restriction.

(i) To operate and provide the features/ functions of the Application and related services.

We use the Collected Data in order to operate and provide the features/ functions of the Application and related services, such as to:
- make the Application work smoothly and safely;
- confirm and analyze the usage status of the Application;
- improve the quality and provision structure of the Application;
- provide customer service, for example by sending notifications relating to the Application (e.g. new features/updates) and responding to your inquiries/requests;
- detect, prevent and manage potential security threats and prohibited activities, and protect or enforce the rights, property, safety or security of ourselves or others; and
- comply with our legal obligations;

(ii) To optimize, improve and develop current and future products and services of SONY Group.

We use the Collected Data in order to optimize, improve and develop current and future products, services and related operations of SONY Group, for example by analyzing your use of the Application.

4. WHO ELSE HAS ACCESS TO THE COLLECTED DATA?

The Collected Data may be made available to SONY Affiliates and to other third parties as well as those you choose to share the Collected Data with, as follows:

(i) SONY Affiliates

The Collected Data may be shared with and used by other SONY Affiliates to pursue the activities related to the purposes set out in this Privacy Policy.

(ii) Service providers

SONY and SONY Affiliates may use third-party service providers to process the Collected Data on their behalf for the purposes set out in this Privacy Policy. Such third-party service providers include, but are not limited to, IT service providers and data hosting providers.

(iii) Business transfer

In the event that SONY or a SONY Affiliate sells or transfers a portion or all of its business, the Collected Data may be transferred by SONY or such SONY Affiliate to the purchasing or acquiring entity as part of the transaction.

(iv) Compliance with law and protection of SONY and others

SONY may disclose any of the Collected Data if required or permitted by law, regulation or order, or if we believe in good faith that disclosure is reasonably necessary for us to protect or enforce the rights, property, safety or security of ourselves or others, to third parties including government authorities and law enforcement officials, and auditors and similar external consultants like lawyers and tax advisors.

(iv) Partners

SONY may disclose any of the Collected Data to third-party partners, such as:
- Google Inc. ("Google"), providing Firebase Analytics used in the Application for analyzing the usage status of the Application. To better understand how Google uses the information it receives, visit: https://policies.google.com/privacy?hl=en-US.

5. DATA RETENTION

SONY will keep the Collected Data as long as it is necessary for the relationship with you or the purposes detailed in Section 3, or necessary 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.

6. TRANSFER OF THE COLLECTED DATA INTERNATIONALLY

The Collected Data may be transferred in harmony with Section 3 and Section 4 to countries/regions outside your country/region of residence, including in particular Japan and the United States, in which the privacy laws may not be as comprehensive as those in your home country/region.

7. SECURITY

SONY Group undertakes reasonable security measures designed to protect against the unauthorized access, loss, misuse or alteration to/of the Collected Data. Although SONY Group strives to protect the Collected Data, SONY Group cannot guarantee or warrant complete security of any Collected Data transmitted to SONY Group through the Application or that SONY Group stores on its systems or that is stored on systems of those third parties contemplated in Section 4.

8. CHILDREN

We are committed to respecting children's privacy. We will not collect personal information (as defined by applicable law) from anyone we have actual knowledge is under the age of 15 or equivalent legal age in their province, territory or country/region, without verifiable consent of their parent or guardian. 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 below.

9. YOUR CHOICES AND RIGHTS

You can request access to, and amendment/deletion of, the Collected Data we hold about you. In some cases, your choices to change or delete information you provide may affect our ability to operate and provide the Application and related services to you. We may decline to process requests which are extremely unreasonable/impractical or not required by law, in particular in order to detect, prevent and manage security threats and prohibited activities, and protect or enforce the rights, property, safety or security of ourselves or others.

10. CHANGES

SONY may revise this Privacy Policy at any time by prominently posting notice of the amendment on the Application. You are advised to consult the posted Privacy Policy regularly for any changes.

11. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our use of the Collected Data, or if you wish to make requests or exercise any legal right you may have in respect of the Collected Data, please contact us at sony-ba-reon-app@sony.com