This privacy policy describes how Sony Thermo Technology Inc of 2-chome-11-1 Konan, Minato City, Tokyo 108-0075 Japan (“Sony”, “we”, “our” or “us”) processes personal information about you in relation to REON POCKET application (“App”) and REON POCKET and/or REON POCKET TAG (“Device”). It also sets out how we use and protect your personal information, and your rights in relation to this information. Sony is the controller of your personal information.
Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. Sony will collect the following categories of personal information from you through Apple Inc. or Google LLC which host the application store to allow you to download the App, use it and maintain it and to send you updates. This will involve the processing of your personal information.
(a) Information collected by us to allow you to download the App, use it and maintain it and send you updates - including OS and its version, Locale and Time zone settings of the OS, device information (model, display size, etc.) and version of the software
Please note that other personal information remains stored in the Device and the App for a limited period and is not sent to Sony. This personal information is information regarding the Device via Bluetooth - including Serial number, Internal temperature of the Device, Sensing data such as surface temperature and humidity, Usage status (stationary/walking, etc.), Operation status, Configuration status and System status (power status, etc.). Sony does not process this personal information and therefore it is not a controller in relation to this personal information. By using the App, you are taking responsibility for the collection and use of other people’s personal information in accordance with applicable data protection laws. You may want to notify others about the sensing technology used in the Device. If you have questions, you can contact Sony at stti-app-contact@sony.com.
Sony does not process personal information about you that would be considered special category data. In addition, Sony does not automatically process your personal information to make decisions or conduct 'profiling' about you.
Sony rely on the following legal basis in order to process your personal information and for the following purposes:
| Legal basis for processing | Purpose |
| To fulfil our contractual obligations to you | • To allow you to download the App and use it. • To send updates for the App. Failure to provide personal information may prevent or delay the fulfilment of these contractual obligations. |
| To meet our legitimate interests | • To maintain the App. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. |
You have certain rights regarding your personal information, subject to local law. These include the following rights to:
• access your personal information;
• rectify the information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• opt-out of processing your personal information for the purposes of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (you may have these rights though we do not engage in these types of processing);
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
• lodge a complaint with your local data protection authority.
If you would like to discuss or exercise such rights, please contact us at the details below.
Sony may share your personal information with third parties under the following circumstances:
• Sony Group Companies. Sony work closely with other businesses and companies that fall under the Sony Group Corporation and may share certain information intra-group. A list of companies within Sony Group Corporation can be found here: https://www.sony.com/en/SonyInfo/CorporateInfo/Subsidiaries/.
• Law enforcement agency, court, regulator, government authority or similar third party. We will share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Business Transfer. We may share your personal information with to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. Should such a transaction or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.
• Professional advisers. In individual instances, we may share your personal information with professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
Since we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on "International Data Transfer" below for more information.
Sony implements technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
We will only retain your personal information after this time if we are required to do so to comply with the law, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.
Your personal information may be processed, stored, and transferred for the purposes outlined in this Privacy Policy from your country to countries which may not be regarded as providing the same level of data protection as your country.
We will put in place appropriate safeguards (such as contractual commitments) to ensure that your data is adequately protected, and transfers of your personal information meet the requirements of any applicable data protection legislation such as the EU standard contractual clauses. For more information on the appropriate safeguards in place, please contact us at the details below.
Sony is the controller responsible for the personal information we collect and process.
If you have questions or concerns regarding the way in which your personal information has been used or if you wish to exercise any legal right you have in respect of your personal information, please contact stti-app-contact@sony.com.
Our representative in the UK is Sony Europe B.V., a Dutch company, whose UK branch has its business address in The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, The United Kingdom. If you have any concerns about how we process your data, 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.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a local data protection authority.
We may modify or update this privacy notice from time to time.
If we change this privacy notice, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g., to object to the processing).
[APRIL 23, 2024]