PRIVACY POLICY

Remarks:
Original versions of (1) Sony Group Japan – Common Corporate Privacy Policy, (2) Public Disclosure etc. on Matters relating Personal Information and/or (3) Cookie Policy are/is written in Japanese under the premise that they apply are to individuals residing in Japan. This translation is provided only for the reference and convenience of non-Japanese residing in Japan. In case of discrepancies between Japanese version and this English version, the Japanese version shall prevail.

Sony Group Japan – Common Corporate Privacy Policy (*)

Sony Design Consulting Inc. recognizes the personal information of customers as their valuable asset in order to provide them with better products and services. When Sony Design Consulting Inc. stores or uses personal information of customers, it strives to protect the information and meet customers’ expectations based on the following Sony Group Japan – Common Corporate Privacy Policy.

Operation Commencement Date: April 1, 2020
Sony Design Consulting Inc.
Yutaka Hasegawa

Each company of the Sony Group (collectively, “Sony”) is willing to build an environment in which the personal information of customers is safely stored, used and handled in line with the intention of customers, as well as gaining the trust of customers, and hopes to continue to provide numerous services, under this environment, which inspire and fulfil the curiosity of each customer.

Under this policy, and in accordance with Sony’s philosophy of being honest and fair, Sony has prescribed the following policy on the handling of personal information, and is working to ensure the proper handling of personal information relating to its customers that it collects.

(*)This Policy encompasses Sony Group Corporation and its subsidiaries within Japan.

Handling of Personal Information

(Definition of Personal Information)
1.
“Personal information” in this Policy refers to information relating to an individual that includes a name, date of birth, or other description, etc., that could be used to identify a specific individual, or that includes an individual identification code. All obtained information relating to customers that does not contain information in itself by which a specific individual could be identified, but which could be used to identify a specific individual by collating it with other information, shall be regarded as “personal information” within the scope that it can be handled in combination with other information.

(Compliance with Laws)
2.
When handling personal information, Sony shall comply with the obligations set forth in the Act on the Protection of Personal Information, various other laws and regulations relating to the protection of personal information, guidelines published by the Personal Information Protection Commission and the competent authorities, as well as to this Policy.

(Use within the Scope of Utilization Purpose)
3.
Except where the prior consent of the individual has been obtained, or where it is permitted by law, Sony shall handle personal information only within the scope required to achieve the previously specified purpose of use, and shall take measures to achieve this.

(Acquisition of Personal Information)
4.
Sony shall endeavour to obtain personal information after expressing in advance the items, purpose of use, and contact point for inquiries, etc., of the personal information to be handled, and after obtaining the consent of the individual. In the event that special care-required personal information such as race and creed, etc., is included in the personal information, except where permitted by law, Sony shall not acquire such personal information without the consent of the individual. When obtaining personal information from a third party, if a legal obligation to check or create records arises when receiving provision from a third party, Sony shall comply with this.

(Personal Information of Customers Under the Age of 15)
5.
Sony shall endeavour to comply with all laws and regulations applicable to the collection, storage, and use of personal information relating to customers under the age of 15. In the event of a child having provided personal information to Sony without the consent of their parent or guardian, we ask that a parent or guardian contacts us at the address specified in this Policy.

(Security Control Action)
6.
Sony shall endeavour to keep the content of personal information accurate, complete, and up to date within the scope of the purpose of use, shall take the necessary and appropriate secure management measures in accordance with technological standards at that point in time in order to prevent unauthorised access, leakage, tampering, loss, or damage, etc., and shall make corrections as necessary.

(Supervision Over a Trustee)
7.
Sony, within the scope required for the achievement of the purpose of use, may entrust the handling of personal information to another Sony Group company or a third party. In such a case, the appropriate secure management measures shall be taken under the Sony Group common information security policy. In addition, with regard to the contracting of business to a third party, efforts shall be made to ensure that secure management is performed as strictly as possible in relation to the handling of personal information, such as through the execution of a contract. If a third party in a foreign country is contracted to perform business, and a legal obligation to create records arises, Sony shall comply with this.

(Third Party Provision)
8.
Except where permitted by law, Sony shall not provide personal information to a third party without obtaining the consent of the individual. If personal information is provided to a third party, and a legal obligation to create records arises at the time of such third party provision, Sony shall comply with this.

(Respond to a Demand etc. for Disclosure etc.)
9.
Sony shall respond appropriately to requests for the disclosure, amendment, ceasing of use (for introducing products and services, etc.), and deletion of personal information, as well as other comments and inquiries regarding the handling of personal information, based on the provisions of laws and regulations. Please contact the address of the company to which you provided information for assistance.

(Strengthening of Systems, Training, Etc.)
10.
To ensure the appropriate handling of personal information, Sony shall endeavour to continually strengthen and improve internal systems, including reviewing this Policy, by appointing a manager for personal information, establishing internal regulations, training officers and employees, and implementing the appropriate internal audits, etc.

Sony Group Corporation – Public Disclosure etc. on Matters relating Personal Information

Operation Commencement Date: April 1, 2020
Sony Design Consulting Inc.
Yutaka Hasegawa

The “Act on the Protection of Personal Information” (hereinafter “the Act”), with regard to personal information that is obtained by the Company (Name: Sony Design Consulting Inc.), which is a business operator handling personal information, prescribes the statutory matters, such as the purpose of use, that should be published or made easily accessible to the individual.
With regard to the items set forth in 1 to 5 below, the Company states the following (the terms, etc., used are the same as those in the Domestic Sony Group Common Privacy Policy).

Information to be obtained: Stated in paragraph 1 of sections Ⅰ through Ⅲ below.
Utilization Purpose: The purpose of use of personal information (related to Article 18 Paragraph 1 of the Act) and the purpose of use of retained personal data (related to Article 27 Paragraph 1 of the Act) at the time of acquisition (hereinafter collectively referred to as “purpose of use”). Stated in paragraph 2 of sections Ⅰ through Ⅲ below.
Joint User and Subcontractor of Personal Information (hereinafter “personal information recipient”): Information on joint users is provided in Ⅲ below. Cases where there is a subcontractor are stated in the items of sections Ⅰ through Ⅱ.
Contact Point: “The address for reporting complaints relating to the handling of retained personal data” prescribed in Article 5 of the “Ordinance for the Enforcement of the Act on the Protection of Personal Information”. Described paragraph 4 of sections Ⅰ through Ⅱ below.
Procedures for responding to requests, etc., for disclosure, etc.: The procedures for responding to inquiries regarding notifications of the purpose of use (Related to Article 27 Paragraph 2 of the Act), disclosure (Related to Article 28 Paragraph 2 of the Act), cessation, etc., of use (Related to Article 30 Paragraph 2 of the Act), and the cessation of third party provision (Related to Article 30 Paragraph 4 of the Act) of retained personal data (hereinafter collectively referred to as “requests, etc., for disclosure, etc.”). Described in Ⅰ-5 below.

Details

Ⅰ. Provision of Services in Business

I-1.
Information to be obtained：
Name, address, telephone number (including the customer’s information where the customer has been specified by another person as the gift recipient, etc.), date of birth, gender, occupation, place of work, email address, credit or debit card information, content and history of comments and inquiries, as well as other information obtained as needed for the provision of services (includes purchase history and TV / online content viewing history)

I-2.
Purpose of use：
The business activities stated below in relation to (a) design consulting, (b) design management, (c) design services

The sale of products or provision of licenses and services
Public relation, promotion, and sales promotion activities (includes use with the purpose of information analysis and marketing. Information may be provided on products and services, exhibitions, and various events by email and direct mail, etc.)
Customer support such as after-sales service (includes use in registration, personal identification, and emergency contact, etc.)
Testing, research and development

I-3.
Personal information recipients：
Some information may be shared with a subcontractor for the purposes of use outlined in Section 2 above.
Information on joint users is provided in Ⅲ-2 below.

I-4.
Contact Point：
Sony (electronics) contact point for requests, etc., for disclosure, etc., of personal information
Address：1-7-1, Konan, Minato-Ku, Tokyo, 108-0075
Inquiry Form：https://www.sonydesignconsulting.com/confirm.html (Japanese only)

I-5.
Procedures for responding to requests, etc., for disclosure, etc.：
Please contact to the Contact Point above. Please note the followings.

We may reject your requests as long as permitted under applicable laws. In this case, we will explain the reasons for the reject.
We may ask you to submit a copy of documentations for proof of identification.
We may charge a fee for your request of disclosure.

Ⅱ. Corporate Communication Activities

Ⅱ-1.
Information to be obtained：
Name, address, date of birth, gender, telephone number, occupation, workplace, email address, content and history of comments and inquiries, other information obtained as needed for the provision of information and various communications.

Ⅱ-2.
Purpose of use：
Provision of information and various communications to reporters, etc., in conjunction with corporate communication activities

Ⅱ-3.
Recipients of personal information：
Some information may be shared with subcontractors for the purpose of use described in 2 above.

(Matters relating to personal information concerning employment applicants and our employees shall be published or notified, etc., to the individual separately.)

III.　Matters Relating to Joint Use (Related to Article 23 Paragraph 5 Item 3 of the Act)

Article 23 Paragraph 5 Item 3 of the Act prescribes, as an exception for third party provision, that in the event of personal data (excluding special care-required information) being used jointly with a specified party being provided to said specified party, and the fact of this along with certain matters being made easily accessible to the individual, said specified party is not applicable as a “third party” referred to in third party provision, and that personal data may be provided to said joint user without obtaining the prior consent of the individual.
In regard to this, there may be cases in which the Company jointly uses personal data that is obtained in accordance with the following items.

III-1.
Items of personal data to be jointly used：
Personal data provided through communications (regardless of whether by the inquiry form on our website, by telephone, or any other form; also includes requests for business discussions) to the customer contact point in relation to design consulting, design management, and design services, and information collected in relation to the items of sections Ⅰ through Ⅱ above

III-2.
Scope of parties to be engaged in joint use：

Sony Group Corporation
Any legal entities controlled* by Sony Group Corporation.

*The term “Control” here 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.

III-3.
Purpose of Use of Using Parties：
The following business activities relating to electronic products, parts, services and their design

Responding to communications to the contact point and other inquiries
Sale of products and provision of related services
Provision of customer support, such as product warranties and repairs
Reference for product development and improving services
Public relation, promotion, and sales promotion activities (includes use with the purpose of information analysis and marketing. Information may be provided on products and services, exhibitions, and various events by email and direct mail, etc.)

III-4.
Party with Responsibility for the Management of Personal Data：
Sony Design Consulting Inc.

Remarks
If the Company separately indicates a specific purpose of use, etc., by means of notification to the individual or approval of the terms of use, etc., such specific purpose of use, etc. shall be applied with precedence over the above. Thank you for your understanding.

End

Cookie Policy

In order to analyse how customers use our website, and in order to provide more customised services and advertising to each individual customer, etc., Sony may use cookies and similar technology to collect certain information.

1．Cookies and Similar Technology

“Cookie” refers to a small text file which, when a customer accesses the website, is sent to the browser of the customer’s computer or mobile device (hereinafter collectively referred to as “device”) from the web server, and is stored on the device’s hard drive.

Cookies can generally be divided into two categories, 1st Party Cookie and 3rd Party Cookie. 1st Party Cookies are set by Sony. Such cookies, in almost all cases, are set for the use of the functions provided on the Sony website. On the other hand, 3rd Party Cookies are set by a third party partnering with Sony rather than Sony itself. For example, some 3rd Party Cookies are set by companies providing advertisement distribution services that are partnering with Sony, in order to track the customer’s browsing activities, so that appropriate online advertisements can be posted in the appropriate location.

“Beacon (or pixel)” is a technology for transferring information from the customer’s device to the server. A beacon can be embedded in email and online content such as images and videos, allowing for servers to read specific types of information from the customer’s device, to recognise that the customer has seen specific content, or has opened / previewed an email, and to record information such as the date of viewing and IP address, etc.

2．Purpose of Use of Cookies and Similar Technology

( 1 ) The cookies and similar technology described above are technologies established so that, when the customer browses the internet in general, or uses a specific online service, the customer’s device is recognised automatically, and the service can be used continuously from the previous time, without the customer having to repeatedly input the same information. Today, it is used to track your browsing activities and display appropriate advertisements on the display screen of your browser.

( 2 ) Sony may use cookies and similar technology for the use of collected information, to analyse how the customer uses the website (access status, traffic, routing, etc.), to improve the performance of the website itself, and for improvements to the services provided to the customer by Sony through the website.
In addition, when performing such analysis, the following tools will be mainly used, and the above information may be also provided to the tool provider and be used for advertisement distribution, etc. to you.

Adobe Analytics

Tool Provider：Adobe Systems Incorporated
Adobe Privacy Policy (Japanese only)
Information collected through the tool: Customer’s website usage status (access status, traffic, routing, etc.)

Google Analytics

Tool Provider：Google Inc.
Google Analytics Terms of Use (Japanese only)
Google Privacy Policy (Japanese only)
Information collected through the tool: Customer’s website usage status (access status, traffic, routing, etc.)

Treasure Data

Tool Provider：Treasure Data
Treasure Data Privacy Policy
Information collected through the tool: Customer’s website usage status (access status, traffic, routing, etc.)

Refer to Article 3 for information on how to stop the provision of information to these tools.

( 3 ) By accessing Sony website, 3rd Party Cookie will be sent from the advertisement distribution service provider as listed in the following Article. 1st Party Cookies sent by Sony are stored with 3rd Party cookies sent by each advertising distribution service company on their respective advertising distribution service company servers, and are handled in accordance with the respective privacy policies. Please refer to the following Article for information on how to stop distribution for targeted advertising, etc.

3．Method for Refusing Cookies and Similar Technology

( 1 ) Method for Refusing All Cookies
Cookies on a customer’s device will remain on the device until they are deleted by the customer or until the fixed expiration period has elapsed. Almost all browsers are set to automatically accept cookies by default; however, a customer may disable cookies by changing the browser settings. It should be noted that, if cookies are disabled, some website functions may become unavailable, and some pages may no longer display correctly, so please bear this in mind. For example, the customer may encounter inconveniences such as being unable to log in and access their Sony account, being unable to make a purchase, or being unable to register a Sony online warranty.

Please refer to the following URLs for information on the most common browsers, and how to change cookie settings.

( 2 ) Method for Refusing Specific Cookies
The method for stopping the provision of information for the tools stated in Section (2) of the preceding Article is stated on each of the following respective URLs. However, if you would like to delete all such cookie information, please be aware that you may be subject to restrictions in the use of the products and services provided by each company.

Main Tool Provider	Privacy Policy	Method for Stopping Information Transmission
Adobe Systems Inc.	Adobe Systems Inc. / Privacy Policy (Japanese only)	Adobe Systems Inc. / Setting of privacy policy (Japanese only)
Google Inc.	Google Inc. / Privacy Policy (Japanese only)	Google Inc. / Google’s opt-out browser add-on. (Japanese only) Google Inc. / Privacy policy (Japanese only)
Treasure Data inc.	Treasure Data Inc. / Privacy Statement	Treasure Data Inc. / Privacy Statement

With regard to targeted marketing stated in Section (3) of the preceding Article, the method for stopping distribution is stated on each of the following respective URLs of the advertising distribution service companies. However, if you would like to delete all such cookie information, please be aware that you may be subject to restrictions in the use of the products and services provided by each company. As for Facebook Japan among the following advertisement distribution service providers, if you are a registered user of Facebook, your browsing history of the website will be managed in a manner linked to such registration information.

Main Advertising Distribution Service Company	Privacy Policy	Method for Stopping Advertising Distribution
Yahoo! Japan Corporation	Yahoo! Japan Corporation. Privacy Policy (Japanese only)	Yahoo! Japan Corporation / Use of personal data for advertising (Japanese only)
Amazon Japan G.K.	Amazon Japan G.K / Privacy Policy(Japanese only)	Amazon Japan G.K / Ad display settings (Japanese only)
Google Japan and Google Network	Google Japan and Google Network / You have choices regarding the information we collect and how it’s used (Japanese only)	Google Japan and Google Network / Block certain ads (Japanese only)
Microsoft Japan Co., Ltd.	Microsoft Japan Co., Ltd. Privacy Statement (Japanese only)	Microsoft Japan Co., Ltd. / See ads that interest you (Japanese only)
Facebook Japan	Facebook Japan / Cookies & Other Storage Technologies (Japanese only)	Facebook Japan / About Facebook Ads (Japanese only)

( 3 ) Method for Refusing Beacons
As web beacons using JavaScript tags are the same as any other content request included in a web page, you cannot opt out or refuse them. However, you can generally disable web beacons in email messages by not downloading images contained in message you receive, this method is dependent on the function of your email software, and it will not necessarily be the case that beacons are always disabled. In such a case, please follow the delivery suspension procedures for the email newsletter to which you are subscribed.