| 1. PERSONAL INFORMATION THAT WE COLLECT AND/OR HOLD
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It is voluntary for you to provide your personal information. However, where you do not provide the information requested , we may not be able to provide you with your requested goods or services.
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| Information that you provide us
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Whenever you interact with us, you may be asked to provide us with information relating to you. For example: |
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• Some of our services require you to create an account, such as My Sony membership on https://www.sony.com.hk/. When creating or using your My Sony membership, we may ask you to provide a range of information, such as your name, contact details, age group, gender, month of birth, interests, account and newsletter preferences, purchase details, place of purchase, product registration;
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• When you join one of our loyalty programs, we may collect information relating to your use of the loyalty program and the rewards that you claim;
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• When you purchase or reserve a product from our stores, we may record the call and/or ask you to provide information such as your contact details, purchase details, delivery date, visit and reservation time, and Sony Store interests, and place of purchase and payment information;
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• When you contact our contact centre or customer service for assistance, via email, telephone, webchat, WhatsApp, Facebook, Instagram or otherwise, we may keep information about and record the call, including your name, phone number, email, enquiry details, the product(s) you bought, the reason why you contacted us, the advice we gave you and we may record your call conversation for the purposes of monitoring the quality of our customer service and marketing;
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• When you contact our customer service for installation, repair or return, premium redemption or otherwise for any our customer support, we may keep your contact details, product repair information, item redemption information, place of purchase and your purchase invoice;
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• When you participate in one of our prize draws or competitions, we may collect your contact details, address, age, or your submitted materials;
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• When you visit us at a public event, such as competition, roadshow, exhibition or seminar, workshop, or participate in one of our surveys or redemption activities, we may collect your contact details, survey information, interests, age, gender, redemption activity information;
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• When you use our online services, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive;
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| Information we may collect from other sources
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We may also collect information from publicly available sources and third parties, including:
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• When you seek to make a purchase from us, we may carry out credit and financial checks to ensure payment is not made fraudulently and that you have a suitable credit rating;
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• If you purchase products or services from a Sony Store or other retailer, we may receive certain information about your purchase from that retailer. We may also receive information about you from other Sony group companies that you interact with;
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• When carrying out business to business sales calls, we may use business contact details that are publicly available
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| Information we may collect in relation to social networks
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If you use any of our social network applications, pages or plugins or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts.
For instance, if you log-in to one of our websites or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings, however, they might include your social network ID, name, profile picture, gender and locale. We may also receive additional information from your profile if you give us permission to access it.
For more information and for details about how you can control access to your social network profile, you should view the privacy policy and other guidance available on your social network’s website.
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| Information we may collect when you use websites, products and services from Sony
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Some of our websites, internet-enabled products and online services provide us with information about your use of them, including:
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• Details of the content that you view and interact with. For example, when you use our website, we may collect information about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket
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• Service, product or server logs, which hold information about your use of our service, product or websites, such as your IP address, browser information (including HTTP user agent strings), HTTP client request information and the time and location of your activities, domain, device and application settings, errors and hardware activity
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• Device information such as your device ID(s) and/or information about where your device is physically located. For example, when you are using a geo-location service or application and you have provided consent to your location being shared
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• Interests and preferences that you specify during setup of the Internet enabled product or service;
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• Emails communications that you have with our customer service, contact center or other Sony personnel may be monitored and logged.
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In general, this information is collected using digital identifiers such as a device number, browser cookie or your IP address. These identifiers are used to distinguish the information provided by your browser or device from that of another user’s browser or device,
We may associate the collected information with one of your accounts, if for instance you are logged into a service when the information is collected.
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| 2. PURPOSES OF DATA COLLECTION AND USE
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Your personal information collected and held by us may be used for the following purposes: |
| Provision of product and services
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(a) provide you with a product or service you have requested (whether from our Sony Store or online stores, including any product or service updates) and checking that a payment is not made fraudulently, and delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and fulfil its obligations under any other agreement it may have with you);
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(b) provide customer service (whether in-person, at our Sony Stores, online, by phone, email, social media, WhatsApp, or otherwise);
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(c) provide customer service and support, installation, warranty, repair, returns and other after sales services;
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(d) conduct and host our events, competitions, roadshows, seminars, workshops and engaging in our redemption activities;
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((e) establish and maintain your account with us, including the creation and maintenance of your My Sony membership;
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(f) provide our checkout assistance service. When you use our online stores, details of any products that you seek to purchase and your email address may be collected as you fill in the checkout form. If you do not complete your purchase, we may contact you using these details to offer our assistance (in case, for instance, you were suffering from technical difficulties).;
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(g) facilitate your use of services provided by Sony group companies such as Xperia Service and Bravia Rewards services;
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| Product and service development
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(h) work constantly to improve our products and services to better meet customer requirements, to ensure data quality, to develop identity management, and to strengthen network and information security. In this context, we may use personal information:
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• for staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other support centers;
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• to measure our performance or ask for your opinions on Sony products and services and conduct product surveys;
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• to develop and improve new and existing Sony products and services, recommendations, advertisements and other communications and learn more about customers’ shopping preferences in general;
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(i) conduct prize draws, contests and other promotional offers;
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(j) post messages to our social media, internet platform or any other means or answer a survey;
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(k) tailor our service to your needs - information on service use may be used to compile aggregate statistics and carry out analysis in order to help us create content and navigation that is most relevant and user friendly to users;
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(l) conduct analytics to better target and provide personalized contents, recommendations or advertisements within any Sony service, or application used by you;
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(m) (with your consent - see section Direct Marketing below) conduct direct marketing including but not limited to promoting, marketing or selling of Sony's electronic products and related products and/or services, as well as communication with members, including contacting you directly to inform you of new services or opportunities;
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| Other
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(n) investigation and settlement of claims, disputes and detection and prevention of fraud (whether or not relating to the products and services provided by us); and
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(o) other purposes directly relating to any of the above.
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Whilst we endeavour to adhere to our strictest guidelines and select only reputable partners in providing the service, our privacy protection does not cover the personal information that you provide directly to third parties (including but not limited to buyers/sellers in online auctions, on-line merchants sites, other hyperlinked website). We advise you to consult with the relevant parties before providing any data.
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3. TRANSFER OF PERSONAL INFORMATION
You acknowledge and authorize your personal information will be retained by us and stored in one or more of our databases. We will maintain full control over and safeguard, according to strict standards of security and confidentiality, but may share your personal information with the following individuals and/or entities whether within or outside of Hong Kong, for any of the purposes set out above:-
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(a) any agent, contractor or third party service provider who provides services to us including analytics and processing, administrative, accounting, customer service, data hosting, logistics distribution, delivery and fulfilment, installation, fraud detection, telecommunications, computer, payment gateway, marketing, insurance, financing, legal, and other professional services to us;
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(b) any branch, subsidiary, holding company, associated company or affiliate of ours including (i) Sony Group Corporation, (ii) any company of which more than 50% of its shares are owned by Sony Group Corporation, directly or indirectly;
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(c) credit reference or debt collection agency or similar provider of debt collection or credit information services to us for purpose of credit reporting, verification and risk management;
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(d) third party advertising partners so that they can better target and/ or personalise advertisements displayed within any Sony service, or any application used by you (whether Sony or not);
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(e) a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation;
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(f) third parties (including professional advisors) to enforce or defend the legal rights of any Sony group company or the terms and conditions of any Sony product or service;
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(g) any person or authority to whom we are under an obligation to make disclosure under the requirement of any law, regulations, rules, codes of practice or guidelines binding on or applicable to us or any of the Sony group companies
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(h) any other person under a duty of confidentiality to us which has undertaken to keep such information confidential;
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(i) any of our actual or proposed assignees or transferees of our rights during our, or the Sony group's re-construction, re-organization or other similar situations.
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(j) persons whom you transact with through our service such as online merchants, any banking, financial or other institutions.
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| 4. DIRECT MARKETING
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In accordance with the requirements of the PDPO, we intend to use and transfer your personal information for the purposes of conducting direct marketing and may not do so unless we have received your consent or written consent (in the case of transfer).
With your consent or written consent (in the case of transfer) (which includes an indication of no objection), we may:
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(a) use personal information, including your name, contact details including email, phone number, WhatsApp, and address for direct marketing purposes;
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(b) conduct direct marketing in relation to the following classes of products and services that we, our affiliates, our co-branding partners and our business partners may offer:
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i) electrical appliances and electronic products and related good, accessories and services;
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ii) telecommunication products and related goods, accessories and services;
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iii) computers, consumer electronics and related goods, accessories and services;
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iv) reward, loyalty, co-branding or privileges programs and related services such as My Sony membership;
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(c) provide the personal information described in (a) to any agent or contractor for the purpose of carrying out direct marketing of the above products and/or services on our behalf ; and
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(d) in addition to marketing the above products and services, share the personal information described in section (a), with any third party provider of any of the classes of products and/or services as described in section (b) for direct marketing purposes in relation to such classes of products and/or services, and we require your written consent (which includes an indication of no objection) for the purposes and will not do so without your written consent.
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| If you do not consent to us using and/or sharing your personal information for any of those purposes, we may not conduct direct marketing to you and provide your personal information to others for direct marketing purposes. You may also subsequently withdraw your consent by writing to our Data Protection Officer at the below address. If you exercise your right to opt out of the use/sharing of your personal information for any of the above purposes, it will mean that we, our group companies and/or third party service providers will not be able to send you any direct marketing, targeted or special offers in the future. Where you exercise your right to opt out to direct marketing, we shall cease to use and transfer your personal information for direct marketing purposes, without charge.
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5. COLLECTION OF DATA USING 'COOKIES'
What are "cookies"?
We may use "cookies" to collect data on the usage of our service by users and to facilitate return visits. A "cookie" is a small piece of information sent by a web server to be stored on a web browser so it can later be read back from that browser. The data collected from cookies is currently used to improve the functionality of our service. The data on our service is organized and presented based on our analysis of the aggregate usage of our service. Cookies are also useful in allowing more streamlined log-in, tracking of transactions and in preserving data between sessions.
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6. SECURITY
We are concerned with the security of your personal data collected and has put in place measures to prevent unauthorized access to that data. Our systems safeguard electronic communications by utilising appropriate security protocols for authentication and authorisation, including SSL, encryption, firewalls and data duplication.
In order to help protect you and others, we monitor use of the Sony properties in order to: identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threat to or misuse of the Sony properties; ensure compliance with the applicable Terms of Service and User Agreements and this privacy policy; investigate violations of or enforce these agreements; and protect the rights and property of Sony, its partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through the Sony properties. If you do not consent to these conditions, you must discontinue your use of the Sony properties.
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7. PERIOD OF RETENTION
We retain your personal information for as long as necessary for the purposes set out in this Privacy Policy, or otherwise agreed between you and us, unless otherwise required or permitted under applicable law. Where we no longer require your personal information for the purposes under this Privacy Policy, or otherwise required under law, we will take appropriate steps to securely delete or destroy your personal information.
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8. UPDATES TO THE PRIVACY POLICY
We are sensitive to users' privacy issues and recognizes the need to update this policy as new features and business services are offered by us. Users will be notified of any changes to the Privacy Policy prior to the change date.
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9. OTHER RIGHTS
We are sensitive to users' privacy issues and recognizes the need to update this policy as new features and business services are offered by us. Users will be notified of any changes to the Privacy Policy prior to the change date.
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(a) check whether we hold any of your personal information; |
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(b) seek access to your personal information held by us; |
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(c) request correction of your personal information; |
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(d) ascertain our policies and practices (from time to time) in relation to the personal data and the types of personal data held by us;
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| We reserve the right to charge a reasonable fee in relation to the time and attendance involved in complying with any request in this regard.
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10. CONTACTING US
For requests to access or correct your personal data, please complete our Data Access / Correction Request Form (You can obtain the said Form at our Home Page (Download Form) or our Customer Services Reception Centre or Sony Store) and post to:
Data Protection
P.O. Box No. 8873 at General Post Office, Hong Kong |
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| For enquiries regarding practices and kinds of personal information we hold, please contact our Customer Hotline at (852) 2833-5129 (HK) or 080-0039 (Macau Toll-free).
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| Please note that under section 19(1) of the PDPO, the data access request would be complied within 40 days after receiving the request form. If the request is unable or has valid ground to refuse to be complied, in accordance with section 19(2) or 21(1) of the PDPO, you will be given a notification of such matter within the same 40 days period.
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