PRIVACY POLICY FOR THE "Music Pro" APPLICATION

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 Section 2 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 Section 9 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 Section 4 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 Section 6 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 about your log in data (for user authentication) of the Application

• E-mail address
• Your Full name
• Android ID

(ii) Information about your purchase data in Music Pro (for billing):

• Your purchase history regarding the Application purchased through Google Play.

(iii) Information about music performance data (for providing studio tuning service):

• Sound tracks (including vocal) which you uploaded through the Application

(iv) Information about your usage history of the Application (for billing and providing Music Pro service):

• Your usage logs (these logs are included when / which studio tuning options are selected)

(v) Information about endpoint created from device token (for push notice to you of completion of studio tuning of your sound tracks)

• Interface for Amazon Web Service created from device token. (This data enables device identification)

(vi) Information about your use status of the Application (for improvement of the Application)

• errors while studio tuning
• which studio tuning options are selected
• access time of the service
• file size of the recorded sounds
• Reason for user’s cancellation to use the Application

3. HOW DOES SONY USE THE COLLECTED DATA?

We use the Collected Data for the following purposes unless they are anonymised so that they no longer identify you. We use such anonymised 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:

• 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;
• comply with our legal obligations;
• verify and confirm payments;
• process user authentication;
• To provide studio tuning service

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, please note that the legal bases we rely on for the above purpose and related categories of the Collected Data are as follows:

(ii) To optimise, improve and develop current and future products and services of the Application.

We use the Collected Data in order to optimise, improve the Application, for example by analysing your use of the Application.

If you are located in the EEA, UK or Switzerland, please note that the legal basis we rely on for the above purpose and related categories of the Collected Data are as follows:

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.

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. The details of the retention period of each Collected Data are as below;

(i) Retention period: Until Sony finishes Music Pro service through the Application.

Information about your log in data (for user authentication) of the Application

• E-mail address
• Your Full name
• Android ID

(ii) Retention period: 10 years and 4 months from relevant purchase.

Information about your purchase data in Music Pro (for billing):

• Your purchase history regarding the Application purchased through Google Play.

(iii) Retention period: Until you download the relevant sound track(s) or until 24 hours after the relevant sound track’s studio tuning has finished.

Information about music performance data (for providing studio tuning service):

• Sound tracks (including vocal) which you uploaded through the Application

(iv) Retention period: For 13 months from when the usage log was recorded.

Information about your usage history of the Application (for billing and providing Music Pro service):

• Your usage logs (these logs are included when / which studio tuning options are selected)

(v) Retention Period: For 13 months from when the usage log was recorded.

Information about your use status of the Application (for improvement of the Application)

• errors while studio tuning
• which studio tuning options are selected
• access time of the service
• file size of the recorded sounds
• Reason for user’s cancellation to use the Application

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 of America, in which the privacy laws may not be as comprehensive as those in your home country/region.

Where information is transferred out of the EEA, UK or Switzerland, we will, to the extent that no statutory level of data protection comparable to the European data protection laws exists in such countries, adopt appropriate measures to ensure that your Collected Data will be adequately protected in those countries. In particular, we may apply the standard contractual clauses published by the European Commission. Where the Collected Data is transferred from the EEA or UK to Japan, the adequate level of data protection is confirmed by the European Commission´s adequacy decision.

7. SECURITY

SONY Group undertakes reasonable security measures designed to protect against the unauthorised 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

This Application is intended for a general audience. 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 16 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.

Privacy Rights for EEA, UK or Swiss Residents:

If you are located in the EEA, UK or Switzerland, you may have the following rights under certain conditions of the European data protection laws with regard to your Collected Data:

• You have the right to access (including a copy of) your Collected Data; to correct, delete or restrict (stop any active) processing of your Collected Data; and to obtain the Collected Data you have provided to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) your Collected Data with another controller.
• In addition, you can object to the processing of your Collected Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
• Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to our processing your data, this will not affect any processing which has already taken place at that time.

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.

You also have the right to complain to a supervisory authority for data protection in the country/region where you live, where you work, or where you consider that a breach of data protection has occurred – although we hope that we can assist with queries or concerns you may have about our use of your Collected Data.

10. CHANGES

SONY may revise this Privacy Policy at any time by posting the new Privacy Policy here. SONY will also notify you of any material changes to this Privacy Policy 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

SONY, a Japanese company, is the controller for the Collected Data. SONY's address is 1-7-1 Konan Minato-ku, Tokyo, 108-0075 Japan.

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 to the following:

If you are in the EEA or Switzerland: Our representative in the EEA and Switzerland is Sony Europe BV, a Dutch company, whose business address is Taurusavenue 16, 2132LS Hoofddorp, the Netherlands. You can contact our representative in the EEA and Switzerland by emailing: privacyoffice.SEU@sony.com. You can also get in touch by writing to Sony Europe BV at the address above or at The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.

If you are in the UK: Our representative in the UK is Sony Europe BV, a Dutch company, whose UK branch has its business address in The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom. You can contact our representative in the UK by emailing: privacyoffice.SEU@sony.com. You can also get in touch by writing to The Privacy Office c/o Sony Europe Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom, or you can contact your local Sony company at http://sony-europe.com.