1. Collection of Information
1.1 Information You Provide To Sony
In General. While Sony does not generally require that you provide us with personally identifiable information in order to visit and use the Corporate Websites, please note that in order to participate in some activities, such as sweepstakes, contests and other promotions (collectively, “Promotions”), chat rooms or bulletin boards, and some products and services we offer that require use of the Corporate Websites, we may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as first and last name, e-mail address, mailing address, telephone number or possibly, a picture) (“Personal Information”). We may also ask you to provide other information about yourself, such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. If you choose not to provide such Personal Information or other information to us, you may not be able to participate in certain activities or use certain products that we offer. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information.
Individuals Under 13. The Corporate Websites are open to all individuals, though some Promotions may have age restrictions. We do not knowingly collect or permit the collection, storage or use of any Personal Information from anyone under 13. If you are a parent or guardian who knows or has discovered that your child under the age of 13 has submitted his or her Personal Information or other information without your consent, permission or authorization, upon request, we will promptly: (a) provide direct notice to you indicating what, if any, Personal Information of your child has been collected and how it has been used and/or disclosed; (b) remove your child’s Personal Information or other information from our database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.
For Promotions. We may offer opportunities to enter into Promotions that we offer, on our own or jointly with a third party. Such Promotions may require registration and the disclosure of both Personal Information and non-Personal Information. In the event that a Promotion is offered jointly with a third party, as a result of your participation in such Promotion, your Personal Information and non-Personal Information may be shared with such third party, which sharing we will disclose to you at the time you provide your information. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other third parties connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore, always carefully read the rules of the Promotion before entering.
1.2 Information Sony Collects Automatically
In addition to any Personal Information or other information that you choose to provide to us via the Corporate Websites, whenever you visit or interact with the Corporate Websites, Sony automatically collects certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access the Corporate Websites and any referring website. (A Device Identifier is a number that is persistently associated with your Device or that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Corporate Websites.
In addition, Sony, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the Corporate Websites (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if Sony associates it with you as a specific and identifiable person, we will treat it as Personal Information.
1.3 Cookies and Other Tracking Technologies.
The technologies used on the Corporate Websites to collect Usage Information, including Device Identifiers, may include:
Cookies. “Cookies” (which may be HTML files, Flash files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit the Corporate Websites or otherwise access our online offerings. Cookies may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your Corporate Website experience. If you choose to disable cookies on your Device, some features of our Corporate Websites and our online offerings may not function properly.
Web Beacons. “Web beacons” (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Corporate Websites, to monitor how users navigate the Corporate Websites, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Corporate Websites, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Corporate Websites, and is deactivated or deleted thereafter.
1.4 Social Media Applications
Functionality on the Corporate Websites may permit interactions between such Corporate Websites and a third-party website, such as enabling you to “like” a product or “share” content to third-party websites. If you choose to “like” or “share” content or to otherwise post information from or via the Corporate Websites to a third-party website, feature or application, that information may become public and the third-party web site may have access to information about you and your use of the Corporate Websites.
You may also choose to participate in a third-party application or feature (such as one of our Facebook applications or a similar application or feature on a third-party website) through which you allow us to collect and share (or the third party to share) information about you, including Personal Information. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or if information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party website or interactive service.
2.Uses of the Personal Information Sony Collects
Sony will use the information it collects, including your Personal Information:
- to tailor your experience on the Corporate Websites;
- to determine which products and services we offer may be of interest to you;
- to process registration and other information you provide via our Corporate Website, including verifying that your email address is active and valid;
- to provide you with information about Promotions or other offerings that may be of interest to you;
- to provide you with support and answer questions or other requests; and
- for other purposes disclosed to you at the time you provide the Personal Information.
We may also use the information we collect to improve the Corporate Websites and our products and services, for internal business purposes, and to contact you with regard to your use of the Corporate Websites and, in our discretion, changes to any of our policies.
3.When and With Whom Sony May Share Information Collected
Non-Personal Information. We may share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties in our discretion for a variety of purposes, including tailoring promotions, advertising and communications we present to you.
Personal Information. We may also share your Personal Information, as specifically disclosed at the time you provide your Personal Information and in the following circumstances:
To Affiliates, Other Sony Companies and Third Parties.
To Third-Party Service Providers Providing Services On Sony’s Behalf. We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your Personal Information with third party service providers that assist us with providing content, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Sony. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your Personal Information may be shared with that Affiliate or third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information in order to host or operate the Corporate Websites, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.
Business Transactions. Sony or any of its assets, including the Corporate Websites, may be sold, or other transactions may occur in which your Personal Information is one of the key business assets in the transaction (such as bankruptcy). In such a case, your Personal Information may be one of the business assets we transfer. Hence, Sony reserves the right to disclose and transfer user information, including Personal Information, in connection with any activity and/or transaction described above (including, without limitation, during the course of any due diligence process).
Legal Protections and Law Enforcement. We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms & Conditions or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the Corporate Websites or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.
4.Links To and Sony Content On Other Websites
The Corporate Websites may contain links to other websites that are operated and controlled by third parties that we do not control. This includes links of advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. In addition, Sony content or widgets may be included on web pages and websites that are not associated with us and over which we have no control. These other websites may send their own cookies to your Device, and they may independently collect data or solicit Personal Information. A link from any Corporate Website to any other website does not mean that Sony approves of, endorses, or recommends that website. Sony provides such links for your convenience and is not responsible for the content of any website linked to or from any Corporate Website. Moreover, Sony is not responsible for the privacy practices of any third party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content on any other website.
5.Notice to California Residents
Your California Privacy Rights: If you are a California resident, you have the right to receive: (a) information identifying any third party(ies) to whom Sony may have disclosed, within the preceding calendar year, your personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information free of charge, please write to us at Sony Corporation of America, 550 Madison Avenue, New York, New York 10022, Attn: Legal Department, or submit your request to www.sonyged.com/en/contact. Sony will respond to these requests within thirty (30) days. Requests that come to Sony by other means may result in a delayed response.
California Online Privacy Protection Act Notice: Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Websites do not currently interpret, respond to or alter their practices when they receive Do Not Track signals. Please note that third parties may collect personal information about your online activities over time and across different websites when you visit our website or other online websites and services. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com
6.Security and Retention
Sony uses commercially reasonable safeguards to help protect and secure your Personal Information, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of Personal Information we share with them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid ‘phishing’ scams, where someone may send you an e-mail that looks like it is from Sony asking for your Personal Information. Sony will never request your Personal Information through e-mail.
You understand that any message or information you send to a Corporate Website may be read or intercepted by others. Sony does not ensure or warrant the security of any information you transmit to us, and you use the Corporate Websites and provide us with your information at your own risk.
7.Consent to Processing
The Corporate Websites are operated in Japan. If you are located in the United States, the European Union, Canada or elsewhere outside of Japan, please be aware that information we collect will be transferred to and processed in Japan. By using the Corporate Websites, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in Japan, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Effective Date: 2018.03.28
INFORMATION THE APP COLLECTS AND HOW WE USE IT
The App does not generally collect name, address, or other contact information from users, other than the limited circumstances set forth below. However, we and our third-party service providers may collect information from Children that is considered “Personal Information” under COPPA in the following circumstances:
- We collect IP address or other unique identifiers that are associated, on a persistent or ongoing basis, with the tablet, mobile phone, or other device used to access the App (“Device Identifier”). We, and our third-party service providers, use Device Identifier information solely to support internal operations, including maintaining, securing, and analyzing the functioning of the App.
- In some instances, we may collect a Child’s email address for one-time use of that information, such as to respond directly to a specific request (for example, responding to a support request submitted through the App or allowing a sweepstakes entry). We delete the contact information provided from our records once it is used to fulfill the specific one-time purpose and will not use it to re-contact the Child.
- We may in the future collect a Child's name and email address to the extent reasonably necessary to protect the security of our App, to protect against liability, or as required or permitted by law. We do not collect a Child’s name or email address for these purposes in the ordinary operation of the App. In the event that we collect information for these reasons, we will not use it for any other purpose.
- If, in the future, features of the App collect Personal Information from a Child other than as described above, we will do so after having secured appropriate consent or otherwise in accordance with COPPA.
Please note that, as required by COPPA, we will not condition a Child's participation in an activity within the App on the Child disclosing more than is reasonably necessary to participate in such activity. We use Personal Information only for the purpose for which it was collected and for internal purposes. We retain Personal Information collected from a Child only for as long as is reasonably necessary to fulfill the purpose for which the information was collected.
We and our third-party service providers may use a variety of technologies that automatically or passively collect certain information whenever a user operates or interacts with the App ("Usage Information"). Usage Information may include the device type and operating system you are using, information about your device’s hardware and components, all of the areas within our App that you visit, and the time of day, among other information. Usage Information is typically associated with your Device Identifier. We may use Usage Information for a variety of internal business purposes, including enhancing or otherwise improving the App and our products and services.
Some features of the App permit Children to share user-created content with other KOOV users – including the opportunity to share details of a robotics project the Child has created using the KOOV product. Children may (subject to permissions set through the Primary Account) elect to share only with a Primary Account holder (e.g., Instructor), with a defined group of KOOV users (e.g., other KOOV users within the Child’s classroom or school), or publicly with all other users of the KOOV service. These features may permit the Child to share “free text,” photos, and videos with other App users. A Sony representative manually reviews each submission from a Child through any feature that may allow the Child to share free text, images, videos, or audio recordings. If the Sony representative identifies any “Personal Information” subject to COPPA, Sony will either (a) reject the entire submission or (b) remove the personal information before the submission is published for viewing by other App users (e.g., by deleting text, cropping or blurring images to prevent the inclusion of a Child, stripping metadata from an image, etc.). In either case, Sony will promptly delete from its own records any Personal Information submitted by the Child. App users may also have the ability to leave comments on public postings made within the App, but may only do so by selecting from pre-populated text or approved emoji. Users do not have the ability to leave free-text comments on public posts or otherwise engage in free-text user-to-user communications.
DISCLOSURE OF COLLECTED INFORMATION
As described above, the Personal Information the App collects from a Child will typically be limited to persistent identifier(s). We do not release a Child's Personal Information to third parties except: (a) where the disclosure is reasonably necessary to comply with law, respond to civil or criminal action, or to protect the security of the App or other properties owned by Sony and its affiliates; and (b) to Sony affiliates and/or service providers who provide support for the internal operations of the App and who do not disclose or use the Personal Information for any other purpose. These affiliates and service providers may provide support services such as hosting App content, designing and/or operating App features, or performing other administrative services. Sony may provide these companies with access to Children’s Personal Information in order for them to carry out the services they are performing on our behalf. These service providers have agreed to maintain the confidentiality, security and integrity of this Personal Information they obtain from Sony and the App. We also may share Usage Information that does not contain any Personal Information (such as aggregated user statistics) with Sony affiliates or other third parties in our discretion.
PRIMARY ACCOUNTS & INFORMATION COLLECTED FROM PARENTS/INSTRUCTORS
PARENT & INSTRUCTORS’ RIGHTS; CONTENT REMOVAL
Parents and Instructors have the right to review and request that Sony delete any Personal Information that the App has collected and retained about their Child or, for Instructors, a Child student. (For purposes of this section, references to “your Child” or similar designations will encompass Child students of Instructors.) If you would like to request that Sony delete any Personal Information we may have about your Child or if you would like to request that the App make no further collection of Personal Information from your Child, please contact Sony as described in the “Contact Us” section below. Note that we will take steps to verify your identity as the Child’s Parent or Instructor and we may need you to provide us with certain information in order to complete your request, as the App does not collect name, email address or other contact information. Where the App is used by an Instructor in an educational setting, these rights of access and removal described in this section will extend to the school and school officials, in addition to the individual Instructor.
In addition, a registered user of the App has the right to request the removal of certain content that (s)he has publicly posted on the App. A Parent or Instructor may remove a post made by a Child Account administered through his/her Primary Account or may delete a Child Account entirely at any time by logging into his/her Primary Account and using the “Player” management features to delete a Child Account or any post(s) made from that account. A Primary Account may also edit a previously made post to remove or modify the username associated with the post. Alternatively, a Primary Account holder may contact Sony using the contact information below to request that a particular post, a Child Account, or the Primary Account itself be deleted or that the username to which a post is attributed be removed.
CONSENT TO TRANSFER
The App is operated from servers located in Japan. Please be aware that information we collect will be transferred to and processed in Japan, the United States and other jurisdictions. By using the App, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in Japan, the United States, and other jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Sony has established and maintains reasonable procedures to protect the confidentiality, security, and integrity of Personal Information collected from users of the App. We also take reasonable steps to release Children's Personal Information, if any, only to verified Parents/Instructors and to service providers and third parties who are capable of maintaining the confidentiality, security and integrity of such information, and who, as described above, have agreed that they will maintain the information in such a manner.
CHANGES TO OUR POLICY