Privacy Policy for “FES Closet” Mobile Application

This Privacy Policy sets out how Sony Corporation, (of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan) (“Sony”, “we”, “our” or “us”) collects and processes various information about you and your interactions with your “FES Closet” mobile application (“App”) when you use it as more specifically explained below (your “personal data”). It also describes your data protection rights, including a right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 below.

This Privacy Policy explains the following items:

i. How Sony reads, collects, uses and/or stores your personal data, including in relation to your use of the App.

ii. How you can contact us and exercise your data protection rights.

1. What personal data is obtained about you when you use the App?

Information automatically collected through the App

When you use the FES Watch U device and the App, the following personal data will be collected from you:

・ Information about your FES Watch U device (i.e. model name, serial number, software version and ID of pre-installed design contents).

・ Information about the App (ID, application version and settings)

・ Information about design contents you download or create on the App (ID and thumbnail image).

(collectively referred to as "Usage Data").

The collection of Usage Data is required in order for Sony to provide the App and device services. If you choose not to provide this information, Sony may not be able to provide all such services to you.

The Usage Data is stored on the device and App only and is not stored on Sony's servers. However, if you choose to have data sharing activated on the App, Sony will receive and store on its servers the following personal data:

・ ID and application version of the App

・ ID of design contents you download on the App

・ Information about your smartphone or tablet (model name, OS version, IP address and language, area and time zone settings)

(collectively referred to as "Shared Data").

Please note that Sony also automatically receives information about how you are using and interacting with the App, for example: information about which of the App functions you choose to use.

We don’t receive personal data about you from third party sources.

2. Purposes and legal basis for processing your personal data

Sony processes your personal data in order to perform its contract with you to provide the App services.

Sony also processes your personal data in order to pursue its legitimate interests in:

1. Improving, developing and marketing products and services

Sony will collect and/or analyze the information referred to in Section 1 in order to improve Sony’s and Sony Group Companies’ products and services and to develop new ones, and to market those products and services so that we can provide improved users’ experiences for current and/or future products and services.

2. Protecting Sony, Sony Group Companies and users of the App

Sony may collect and/or analyze the information referred to in Section 1 in order to identify potential security threats and to protect Sony, Sony Group Companies and users of the App.

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

We also process your personal data where required to do so by applicable law, for example in response to requests by government or law enforcement authorities conducting an investigation.

3. Who else has access to your personal data?

Your personal data that is communicated to and stored by Sony will be made available to other Sony Group Companies and to third party as follows:

Sony Group Companies and third party contractors

We will share your personal data with third party contractor which provides data back-up service to us, and which is located in Japan. The contractor is engaged for the purposes of pursuing the activities outlined in this Privacy Policy on Sony’s behalf, acting as processor of Sony.

Google Analytics

The App uses Google Analytics, a service provided by Google Inc. (“Google”). Google Analytics will use cookies or a persistent identifier connected to your device to analyze use of the App. To better understand how Google uses the information it receives, visit www.google.com/policies/privacy/partners/. Such information will be used by Google in accordance with Google's Privacy Policy: http://www.google.com/privacypolicy.html.

Business transfer

In the event that we sell or transfer a portion or all of our business, your information may be transferred by us to the purchasing or acquiring entity as part of the transaction. In the event we sell or transfer your information to a purchasing or acquiring entity you will be duly informed.

Compliance and enforcement

We will 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. Data Retention, Managing Your Information

We will retain your personal data for 6 months after receipt of the personal data. If you would like us to delete the information, please contact us as described in Section 10 below and we will respond in a reasonable time and manner. Please note that we may be required to retain certain information by law.

5. International Transfer of Your Information

Your information will be processed, stored and transferred for the purposes outlined in this Privacy Policy to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan. 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.

Sony takes appropriate measures to ensure that all transfers of your personal data from the EEA to countries outside the EEA meet the requirements of applicable EU data protection legislation. If you have any questions or concerns about Sony's data transfer arrangements please contact us using the details at Section 10.

6. Security

Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of your information. Although we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to us through your App or that we store on our systems or that is stored on our third party contractors’ systems.

7. Our Policy Regarding Children

Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries. If you are a parent or guardian and are concerned that your child has provided us with personal information without your consent, you should contact us as indicated in Section 10 below.

8. Privacy Rights (including California Privacy Rights)

In some countries, including countries in the EEA, you have certain rights with respect to the personal information Sony holds about you. These include rights to: request a copy of the personal information that we hold about you, request that we correct personal data if it is inaccurate, request that we erase or block your personal data, and to object to our processing of your personal data. If you would like to exercise any of these rights, please contact us as described in Section 10 below.

As of January 1, 2005, California Civil Code Section 1798.83 (the “Code”) permits users who are California residents to request certain information regarding the disclosure of personal information to third parties which is used for their direct marketing purposes. To make such a request, to which Sony shall respond to the extent required by the Code, contact us as described in Section 10 below.

9. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (whenever necessary under the applicable law) of any changes to this Privacy Policy through the App.

10. Contact Information

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you have in respect of your personal data, please contact us at:
[https://fashion-entertainments.com/inquiry/inquiry]

If you are not satisfied with how we have handled your questions or concerns, or have any complaints about how we process your personal data, you have the right to complain to the local data protection supervisory authority in the place where you live or work or in the place where you believe a breach may have occurred.