Privacy policy

Sony Network Communications Europe – Privacy Policy

This Privacy Policy was last updated in September 2021, prior policies are archived here and here.

Please note that other companies in the Sony group are responsible for their respective personal data processing activities in connection with other Sony products and services. These Sony group companies may have their own privacy policies, which are generally available from the relevant websites for those products and services. Click on the relevant section heading to reach that section:

1. Overview
2. Common privacy terms explained
3. Information that we collect as a controller
4. How SNCN use personal data as a controller
5. Sharing information about you
6. International transfers of your information
7. Security of your information
8. Cookies and similar technologies
9. Access to your information and your rights
10. Retention of personal information
11. Links to other sites
12. Children's privacy
13. Contact us

1. Overview

Sony Network Communications Nordics, filial till Sony Network Communications Europe B.V. ("Sony", "we" or "us") develops and markets B2B products and services, including Visilion, mSafety and Nimway ("Service / Services").

Sony Network Communications Nordics is the Swedish branch office of Sony Network Communications Europe B.V., a Sony Group company registered in the Netherlands.

This privacy policy describes how we collect, use, store, and share data about you. Other companies in the Sony group are responsible for data processing in connection with other Sony products and services.

2. Common privacy terms explained

Privacy and data protection law can get technical. Below is an explanation of some of the most common (and important) jargon words used. (Please note this is not legal advice).

GDPR– Regulation 2016/679 of the European Parliament and Council
Personal data – data from which a person can be identified (either in the data itself or when combined with other data)
Controller – the person or company who decides why (purposes) and how (means) personal data is processed and is primarily responsible for securing the rights of data subjects. This is not always the company who collects or works with the data.
Processor – the person or company who acts on personal data under the instruction of the Controller (includes collecting, organizing, analyzing, and storing it)
Data subject – the person to whom the personal data relates
Collect – obtaining a copy of data
Purposes of processing – what the goal of processing is (e.g. marketing).
Grounds for processing – the legal basis that permits processing (e.g. consent)
Legitimate interest – a goal / business objective of a processor or third party, weighed against its privacy impact and effect on the fundamental rights of the data subject (a common ground for processing under the GDPR)

3. Information that we collect as a controller

a. Information you submit

You may provide us your personal data in many ways. Examples include:

submitting forms on our website;
searching on our website;
creating and configuring a partner account in our website;
interacting with us or our customer support (e.g. via email, ticket systems, call centres, or other problem reporting). This information may be logged and monitored;
interacting with us at trade shows or exhibitions or responding to surveys;
using our mobile applications and other applications.

b. Information we may collect from other sources

We may also collect personal data from publicly available sources and third parties, including:

financial and credit information institutions when you seek to make a purchase from us;
publicly available information relating to business contacts for B2B customers;
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; and
when carrying out business to business sales calls, we may use business contact details that are publicly available.

c. Information we may collect from social networks

We use social networks such as LinkedIn to research potential customers, understand their needs, and connect with their representatives. This may include information about content you post, view, like, or follow. These may allow us to learn more about your background, interests, and preferences. We use this information solely as set out in this privacy policy. For more information about how your social networks collect and process personal data, see their privacy policy.

d. Information we may collect when you use our websites, applications and services

Some of our websites, applications and services provide us with information about your use of them, including:

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;
service or server logs, which hold information about your use of our service, 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 and domain, We collect full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
your account data;
your device geo-location if you consent to us collecting it;
your device (ID) and other device data, for example operating system data, language code, country or region, operational status of your device, IP address used by the device; and
application data, for example application version, time stamp related to the use of the application on your device, usage status and usage history.

In general, this information is collected using digital identifiers such as 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 your profile. Please see our Cookie policy for further details.

4. How we use personal data as a controller

Where Sony Network Communications Nordics determines how and why we use personal we collect – i.e. where we are the ‘controller’ – we process it for the following purposes:

a. Marketing

When we use personal information for marketing purposes, either, we base the processing on prior consent, where appropriate – e.g when you opt-in to marketing messages, or our legitimate interests to know our customers, keep you up-to-date about our latest products and services, and to personalise your customer experience. Sony Network Communications Nordics does not use end user data from our services to target marketing towards end users.

You may be given the opportunity to opt-in to (or where applicable law allows, opt-out of) receiving newsletters and other communications from us and/or other Sony group companies. Communications may include details about the latest Sony products and services, upgrades, and special offers in which you may be interested. If you wish to unsubscribe at any time, just follow the unsubscribe information provided in that communication (usually at the bottom). If that doesn’t work feel free to contact us.

You also have the right to object at any time to processing of your personal data for direct marketing in general – just contact us.

Please note:

you must unsubscribe separately for each email address you have used to interact with Sony Network Communications Nordics;
you unsubscribe for each newsletter or communication individually. If you wish to unsubscribe for all marketing communications from us, please contact us
you cannot unsubscribe from important information about our Services you use or have used (such as order confirmations, safety announcements, and account related communications)

b. Service provision

When we use personal information to offer our products and services to you, the processing is based on an agreement between you and Sony Network Communications Nordics. In this context, we may use personal information to:

Provide you with a product or service you have requested, including checking that a payment is not made fraudulently, 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)
Provide customer care, warranty, returns and other after sales services
Facilitate and process your searches and requests for information when you contact us about our products, apps and services

c. Product and service development

We work constantly to improve our products and services. We base this processing on our legitimate interests to develop 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:

For staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other support centres
To measure our performance or ask for your opinions on Sony products and Services and conduct product surveys

d. Security

We may use information collected from monitoring our websites, online services and emails for security purposes. This information may be passed to the police or to other appropriate authorities. We base this processing on our legitimate interests to protect you and our company, systems, employees and partners, or on a legal obligation to cooperate with competent authorities.

e. Fraud prevention and investigation

We may use personal information to prevent fraud and to investigate violations of our policies. For example, we may use your information such as your device ID(s) to ensure that any discounts relating to any promotions are not being redeemed fraudulently, and to check that a payment is not made fraudulently. In this case, we base the processing of personal information on our legitimate interest to prevent fraud and to provide benefits only to our customers.

We may also use personal information to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies. We may use your personal information to enforce or defend the legal rights of any Sony group company or the terms and conditions of any Sony product or service. In this case, we base the processing on a legal obligation to which Sony is subject or on our legitimate interest to defend our legal rights.

f. Anonymized statistics

We may create anonymous, aggregated statistics about the use of our websites, applications, content, products, and services.

5. Sharing information about you

In general, Sony Network Communications Nordics does not sell, rent, or otherwise disclose personal data to third parties without consent.

However, there are exceptions:

a. Our service providers

We may use third party service providers (data processors) to process your personal information for the purposes outlined above. For example, for fulfilling orders, delivering packages, sending postal mail and emails, providing marketing assistance, processing credit card payments, providing fraud checking services and providing customer services. Our data processors operate only in accordance with our instructions, in line with this policy, and are subject to appropriate confidentiality and security obligations.

b. Our legal and business purposes

We may use and/or disclose: (i) to government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies; (ii) to 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; (iii) to a purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation.

c. Anonymous statistics

We may share these with any third party (such as our partners, advertisers, industry bodies, the media) and/or the general public (as you cannot reasonably be identified).

d. Where you publish or share information

If we offer a forum or similar upload area, content you upload and share (including without limitation messages, photos, videos, and links) may be viewed and/or downloaded by other users. You should not expect any information that you make available to others via our online services to be kept private or confidential. Content and links that you share might, for instance, be forwarded by your recipients to others. You should always exercise discretion when using such services.

e. Where you instruct us to do so

We may offer a service that allows you to share information with other platforms or services. In this case we will only share your information if you explicitly instruct us to do so. If you do so, further processing of that personal data by the platform or service receiving it is governed by their privacy policy. So, for example, to delete their copy of this data you must contact them.

Please note any sharing of data instructed by or via your Provider when we act as a data processor is regulated by their privacy policy.

6. International transfers of your information

Sony Network Communications Nordics processes data within the territory of the European Union. Data of EU citizens is not transferred outside the territory of the European Union.

7. Security of your information

Sony Network Communications Nordics takes a number of steps to protect the information covered by this privacy policy from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access when in our systems. This includes, where appropriate: (a) using Secure Sockets Layer (SSL) encryption (designed to make data unreadable if intercepted between sender and intended receiver) when transferring sensitive information; (b) limiting access to the information we collect about you (for instance, to those personnel who need your information to carry out their business activities); (c) putting in place physical, electronic, and procedural safeguards in line with industry standards.

8. Cookies and similar technologies

We use cookies and similar technologies on our websites to better understand your wants and needs. For more information see our Cookie policy. We do not use cookies on applications.

9. Access to your information and your rights

If you would like a copy of the personal information that we store about you in our customer databases, please contact us. We reserve the right to charge a fee for this if permitted by applicable law.

Your local laws may provide you certain legal rights relating to privacy and personal data.

In Europe: You have the right to access your personal data held by us, obtain a copy of it, have us correct it, and have us delete it. You have the right to object to certain types of processing and to withdraw consent you may have given (note this does not affect any processing done before you revoked your consent and we may have other grounds on which to continue to process your data). You have the right to data portability, i.e. the right to receive your personal information in a structured, commonly used machine-readable format and transmit your personal information to another data controller.

To exercise these rights, contact us. We may ask you for proof of identification to verify it is really you making the request.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.

10. Retention of personal information

We will only retain your personal information for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with applicable laws and regulations concerning the mandatory retention of certain types of information.

11. Links to other sites

Some of our websites may contain links to other websites that are not operated by Sony Network Communications Nordics including websites operated by other Sony group companies. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those other websites. You should view the privacy and cookie policies displayed on those websites to find out how your personal information may be used.

12. Children's privacy

We consider a child to be anyone under the age of 16. We do not knowingly seek or collect personal information from or about children.

13. Contact us

Website: https://www.sonynetworkcom.com/contact

Post: Sony Network Communication Nordics, filial till Sony Network Communications Europe B.V., The Point, Hyllie Stationstorg 32, 215 32 Malmö, Sweden.

Email: legalnotices.nce@sony.com