News Suite : Privacy Policy

Data Protection Notice for Customers Using News Suite Application

News Suite Application Privacy Policy

Last Revised and Effective Date: 2023-10-01

[Language : English]

This Privacy Policy explains the following items.

(i) How Sony Group Corporation, (“Sony”, “we”, “our” or “us”) will process (e.g. read, collect, use, share and/or store) personal data about your use of the News Suite application and the content you access through the application. This Privacy Policy only applies to the information collected by and through the News Suite application and does not cover any information collected at any other application or website or offline by Sony (unless specifically stated).

(ii) How you can contact us.

1. About the News Suite service

The News Suite service aggregates information from multiple online sources (such as news feeds with Really Simply Syndication (RSS)). You can access the service via the News Suite application that is pre-installed or can be downloaded to your device. Using the application, you can select which online sources you wish the service to aggregate. The application’s user interface will then display the combined information to you in one place as a single feed. In addition, the application has a feature that displays details about online sources that we believe you may be interested in receiving information from based on the content that you access via your News Suite application.

2. Which personal data about you do we collect?

Personal data covers all information about a specific or specifiable natural person which you notify to us or which is generated or collected by us. When you use the News Suite application, the application may read and communicate to us, for our processing, the following types of personal data for the purposes described below in Section 3. Much of this information is collected automatically as you use the News Suite application.

2.1 Your News Suite application settings: For example, the country and language you selected during setup and whether or not you have enabled certain features, and which news feeds with RSS you have registered to receive information from.

2.2 Your device information: For example, model name, version, OS settings, installed apps, Advertising ID and your IP address.

2.3 Unique ID: Data that is automatically generated when you first start using the News Suite application.

2.4 Information about your use of the News Suite application: We may also collect data about your content browsing history and preferences while using the News Suite application, including the date and time of your visit, which news feeds you read and which posts you share with others. When you use our websites, data on your usage (such as the date and time of your visit, pages called up and files requested, type and version of the web browser used by you, type and operating system of the end device you use as well as your IP address) is temporarily stored in a log file on our server.

2.5 Upload History Log (Android smartphone, Android tablet, iOS smartphone and iOS tablet): For quality and feature improvement purposes, this new feature sends usage statistics of News Suite and Systems to the Sony server. You may incur a charge for data communication when you connect with a cellular network

This feature requires an Internet connection.

"Upload History Log" settings can be altered.

Please note that the News Suite application may read and communicate the information above to us, even if the application is not currently displayed to you on your device.

2.6 Advertising ID: All of Personal Information collected by us will be uploaded in connection with an Android Ad ID or an Identification For Advertisers (IDFA) provided by iOS. Such Advertising ID can be reset by you in the setting on your device.

3. What do we use your personal data for, on what legal basis and for how long?

3.1 Provision of the application and rendering of services

The processing of certain data (i.e. the data listed in 2.1, 2.2, 2.3) is necessary in order to provide the application and render the services and thereafter to ensure the system security. This includes in particular (i) to provide you with the features and functions of the News Suite service that you request, (ii) in order to help the News Suite application and service run better, to provide you with software updates, to develop and introduce new features and functions for the News Suite application and service, and (iii) to enforce and ensure compliance with the terms of use for the News Suite application and service and this Privacy Policy.

The legal basis for the processing is the performance of a user contract with you (Art. 6 (1) letter b GDPR), respectively our legitimate interest in providing the application with our services (Art. 6 (1) letter f GDPR). The processing is a mandatory prerequisite for the use of our application; no objection right is hence available.

This data will be deleted when the above mentioned purposes are fulfilled and a legal basis no longer exists, latest after 6 months. That data may then be assessed in anonymised form for statistical purposes and to improve the quality of our internet presence.

3.2 Customized and Localized Services

You have the option that we customize the services and the content shown to you based on suggestions that may be personalized using, in particular, the information we collect about your use of the News Suite application.

For this purpose, we monitor your surfing behavior on the application from certain data (i.e. the data listed in 2.3, 2.4, 2.5 and 2.6). We may link between such data and other data we collect or the data we are provided by other company.

The legal basis for this processing is your consent based on Art 6 (1) (a), Art. 7 GDPR. You may withdraw your consent with effect for the future at any time.

3.3 Your queries

Should you submit queries to us via a contact form, per e-mail or via a service telephone, we process the information given therein to answer your query as well as the IP address and date/time of the request in order to avoid misuse of the contact form.

The legal basis for the processing is our legitimate interest pursuant to Art. 6 (1) letter f GDPR in providing you with the aforesaid “queries” service. If your query concerns the initiation or processing (including customer service or warranty) of a contract, the additional legal basis for the processing is Art. 6 (1) letter b GDPR.

You may oppose the processing of your data on grounds of Art. 6 (1) letter f GDPR. In this case, upon proving mandatory reasons for the processing we can continue the processing. This can, in such case, be particularly necessary in order to prove past queries and communications with you. If no such mandatory reasons exist, we will cease our communication with you and delete already collected data.

This data will be deleted when our communication with you has ended, i.e. when the factual situation at issue has been conclusively clarified and no further legitimate interest exists for the storage, respectively no further statutory obligations exist to store such data.

3.4 Advertising and product development, right of objection

We also wish to use the data (i.e. the data listed in 2.3, 2.4, 2.5 and 2.6) entered by you in any event or collected during your use of the application to inform you about other products and services or to improve our product offers and services (product development). For this purpose, we use the data in manners as below.

3.4.1 Anonymised usage data

We use the anonymised and/or aggregated data collected with the aid of analysis tools, to be able to understand the surfing behaviour of all visitors and therewith improve the design of our application and of our product range in general. For details of the analysis tools, see point 4 below.

3.4.2 Personalised and pseudonymised usage data

Moreover, we use your data to assist us with the development of entirely new products and services, understand your surfing behaviour and thereby improve the offers displayed to you.

3.4.3 Direct marketing

On our application, we will process your data to provide you with targeted and contextual advertising and offers both within the News Suite application and elsewhere online.

Also without consent, we may inform you where appropriate within the legally permissible scope by advertising using pop-up function of the News Suite application .

You may at any time wholly or partially object to the creation of pseudonymised data, the use of your personal data for advertising and product-development purposes as well as the ensuing contact for such purposes in a specific form or may revoke any consents you may have granted. Please use the corresponding functions that are already provided for your use (e.g. the unsubscribe function in your application) or address a corresponding written notification (reference: data protection) or pop-up function in the app.

The legal basis for the processing is your consent (Art. 6 (1) letter a GDPR) and our legitimate interests (Art. 6 (1) letter f GDPR, where applicable in connection with Sec. 7 para. 3 German Unfair Competition Act (UWG).

This data will be deleted by us following your objection, respectively revocation of any consents given, or otherwise upon the end of your use at the latest, respectively it will only be stored in aggregated, anonymised form. To the extent necessary, we will store the fact that you have objected in order to prevent you being contacted further.

4. Transfer of the data

4.1 Transfer of data to data processors

We partially use service providers, in observance of the statutory requirements, by means of data processor relationships, i.e. processing is performed on the basis of a respective contract, for our account, according to our directions and subject to our control.

Data processors are, in particular

(a) News searching function by keywords utilizes Bing, provided by Microsoft Corporation. The keywords you input will be sent to the server of Bing. Please refer to the Microsoft Services Agreement (https://windows.microsoft.com/en-us/windows/microsoft-services-agreement).

(b) Message display function for Android smartphone or tablet utilizes Firebase Cloud Messaging (FCM), provided by Google Inc. Messages you receive and your user log will be sent to the server of Google Inc. and such information may be used for FCM and/or in accordance with Google’s Privacy Policy (https://www.google.com/privacypolicy.html). In addition, advertisement delivered by Google Inc. may be included in the message you receive.

(c) Message display function for iOS smartphone or tablet utilizes Apple Push Notification service (APNs), provided by Apple Inc. (“Apple”). Messages you receive and your user log will be sent to the server of Apple and such information may be used for APNs and/or in accordance with Apple ’s Privacy Policy (https://www.apple.com/privacy/).

(d) Your information may be stored and/or processed by third party contractors of Sony that Sony uses to provide services that assist in the provision and operation of the News Suite application and service (see under 5).

In such cases we remain responsible for the data processing; the transfer and processing of personal data to or by our data processors is made on the legal basis upon which we are permitted to process data in each case. No separate legal basis is required.

4.2 Data transfer to third parties

We partially also transmit your data to third parties, i.e. partners with whom we collaborate outside of a contracted processing. Such partners render their services on their own responsibility; the processing of your data by our partners is exclusively governed by the data protection notices of such third party.

4.2.1 Sony group companies

Your information may be shared with other Sony Group Corporation's group companies for the purposes as below.

(a) Improvement of the service or application and new product development

The legal basis for the transfer and processing by the Sony Group Corporation's group companies is their legitimate interest pursuant to Art. 6 (1) letter f GDPR to improve their product offers and services, from which you as a user also will benefit.

You may oppose the processing of your data on grounds of Art. 6 (1) letter f GDPR. In this case, upon proving mandatory reasons for the processing we can continue the processing. If no such mandatory reasons exist, Sony Group Corporation's group companies will delete your information.

4.2.2 Business transfers

Your information may be transferred by us as part of a transaction whereby we will transfer all or part of our business, in which case information held by us about our customers will be one of the transferred assets.

4.2.3 Compliance

We may retain, use and/or disclose any of your information as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.

4.2.4 Social networks

To the extent you want to share one of our applications in a social network (e.g. Facebook or Twitter) and for this purpose click one of the “share” buttons, the respective information will be transferred to the social network. Of course, you have to be logged into the respective social network. The legal basis for the transfer is our legitimate interest to provide you with the opportunity to “share”, Art. 6 (1) letter f GDPR.

4.3 Data transfers to other countries

Your information will be processed, stored and transferred for the purposes set forth above in Section 3 to countries outside the European Economic Area (EEA), Japan and/or your country of residence. Your information will be processed by staff operating outside the EEA and/or your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries. Data protection and privacy laws in these countries may not offer the same level of protection as in the EEA and/or your country of residence and you may have fewer legal rights in relation to your information.

Should this include business seats in countries outside the European Economic Area, that are not subject to any adequacy decisions by the EU Commission, we will ensure the protection of your personal data, as well as the enforceability of your rights concerning adequate guarantees (e.g. via data protection clauses, which the EU Commission has enacted or authorized). Please contact us (see Sec. 9), should you need further information on this or wish to receive a copy of the guarantees.

5. Processing of your Advertising ID

5.1 What is Advertising ID?

Our partners and we use so-called “Advertising ID” to fashion our application in a most user-friendly way and to enhance the relevance of advertisements for the users of our application. The Advertising ID is a unique identification number, which provided by the operating system of your mobile device (iOS or Android) and can be regenerated or completely deactivated at any time in your device settings. For mobile devices with an iOS system, this unique identification number is called "IDFA" and for mobile devices with an Android system "ADID" (both in the following “IDFA/ADID”).

We use tools to process your IDFA/ADID to provide you with personalized advertising and to statistically evaluate the use of our app for optimizing our offer for you. Furthermore, we use IDFA/ADID to provide you with a comfortable use of our application.

5.2 For which purposes do we and our partners use your IDFA/ADID, on what legal basis and for how long?

On this application we use tools of third parties to process your IDFA/ADID for two types of purposes: (1) optional for analytics and (2) optional for targeting and advertising purposes, generally set by third-party providers:

Tools for analytics

Analytics tools gather general information on how users use the application, e.g. which pages they visit most frequently and whether they receive any error messages from applications. The data collected with these tools will not be merged with any other information on the visitors of our application. All information collected with the aid of such tools exclusively serves the purpose to comprehend and improve the functionality and services of the application. We use the following tools of third parties for analytics:

• Google Analytics (Google Inc):

https://policies.google.com/privacy

• Storage period: 26 months

The legal basis for this processing is your consent obtained by means of the consent banner displayed upon access to our application (Art. 6 (1) lit a GDPR). When you visit our application for the first time, the entry page will show information on privacy and respective wording regarding the consent to the use of your IDFA/ADID. By clicking “agree”, you agree to the use of these tools and such consent will be stored in your application, so that the information does not have to be repeated on every page of our application. You can revoke this consent at any time with effect for the future in the settings of our application.

Targeting and advertising tools

Targeting and advertising tools are used to better customise advertisements to your interests. They limit the number of times the same advertisement is shown to you, evaluate the efficacy of an advertising campaign, and analyse how the viewing of a certain advertisement influences the conduct of individual users. Such tools are usually placed by advertising networks with the consent of the respective application operator (in this case us). They register a user’s visit of the application and either pass such information on to other entities, e.g. advertising companies, or directly adapt advertisements accordingly. Frequently, they are linked to certain application functions provided by such third companies. We use these tools to create a link to social networks, which in turn may use the information on your use of the application to customise advertisements on other applications to your interests, and also to provide the advertising networks used by us with information about your visit so that, based on your browsing behaviour, you will be shown exactly such advertisements as may potentially interest you. Also in these cases the data collected via such tools will not be merged with any other information on the visitors of our application. We use the following tools of third parties for advertising:

https://socialife.sony.net/privacy/adnetwork_ww.html

You can object to the processing by limiting access to IDFA/ADID in your settings. You can make your objection centrally in the app. Therefore, please go to the "Privacy" section in the settings and uncheck the relevant box or find our instructions in the following link:

https://support.tvsideview.sony.net/5/tvsideview/apn_opt_out/top_en/index.html

Please note that advertising and analytics companies may still collect information from you and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online or on your device. The News Suite application is an advertising supported application. If you wish to stop the collection of data entirely by these service providers or prefer not to receive any advertisements, you must uninstall the News Suite application.

6. Security

We and our service providers take technical and organisational security measures to protect your personal data managed by us against accidental or deliberate manipulation, loss, destruction or access by unauthorised persons. Our data processing and our security measures are improved on a constant basis according to the technical developments.

During the transfer of your personal data to us it is encrypted with Secure Socket Layer (SSL). Personal data which is exchanged between you and us or other participating enterprises is fundamentally transmitted via encrypted connections which meet the latest technical standards.

Our employees and our retained service providers are naturally obliged to maintain confidentiality.

7. Your rights to information, correction, blocking or deletion

Every natural person whose personal data we process has, in principle (i.e. depending on the respective preconditions), the following rights vis-à-vis us:

• Should you have questions regarding our processing of your personal data, we would be pleased to provide you at any time and at no charge with information on the data stored about you (Art. 15 GDPR).

• You have a right to the correction of incorrect data as well as completion of incomplete data (Art. 16 GDPR).

• You have a right to the blocking/limitation of the processing or to deletion of personal data concerning you which is no longer required or stored on grounds of legal obligations (Art. 17, 18 GDPR).

• You have a right to the transfer of the data in a structured, standard and machine-readable format, insofar as you have provided us with the data on grounds of a consent or contract between us and you (Art. 20 GDPR).

• You have the right to object at any time to the processing of your data for direct marketing purposes (cf. also clause 3.4; Art. 21 para. 2 and 3 GDPR).

• You have the right to object to a processing on the basis of legitimate interest, in which case we are entitled to demonstrate our compelling reasons (Art. 21 para. 1 GDPR). We have pointed out above (clause 3) in which cases this right applies.

• Insofar as you have consented to a data processing, you can revoke this consent at any time with effect for the future, i.e. the legality of the data processing remains unaffected until the date of the revocation. After a revocation of consent, you may no longer be able to use our services.

Please address your concerns through contact form given in point 11 below. We reserve the right to check your identity to ensure that your personal data is not disclosed to unauthorised persons.

Furthermore, you are entitled to file a complaint with a supervisory authority for data protection.

8. Data protection contact

For further information on our Privacy Policy, including inquiries, complaints, or disputes related to the collection and use of your information, please submit your request via

https://socialife.sony.net/en_ww/newssuite/contact/privacy/

9. Amendments

From time to time the content of this data protection notice may have to be modified. We therefore reserve the right to amend them at any time. We will also publish the amended version of the data protection notice at this place. We will post the revised version, with an updated revision date, at the menu of “Privacy Policy” in News Suite application and/or on our website, and the changes are effective when we post them (or on such date as indicated in the updated policy). When you revisit us, you should therefore reread the data protection notice.