Privacy Policy for the “Open Devices” website
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, uses, stores and otherwise processes Collected Data (defined below) in connection with the “Open Devices” website (“Website”).
It also describes your data protection rights, including the 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 6 “Privacy Rights” below.
Please note that this Privacy Policy only applies to this website and is applied in addition to any other privacy policy that may apply to your interactions with any Sony Group Companies (defined below) or third party regarding their product, software or service.
1. Definition
1.1 “Collected Data” has the meaning set forth in Section 2 below.
1.2 “Sony Group Company” means Sony Group Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony Group Corporation (the term “control” in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity).
2. What information is collected?
Sony collects data as described below, which may include personal data (collectively, the “Collected Data”). For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of “Controller” and “Processor” are defined, Sony is the “Controller” of the Collected Data.
2.1 Information that you provide to us
To use the Website and some of our applications and services, you may be asked to provide us with information relating to you.
For example:
- When you contact the Website for legal requirements based on section 6 (Privacy rights), as well as to obtain product or service support, we may collect personal information, such as your name, email, company name and the inquiry content.
- When you unlock an Xperia device, we may collect the IMEI number to generate an unlock code.
2.2. Cookies
Sony uses cookies and similar technologies across the Website. More information about our use of cookies is available in our Cookies policy.
3. How does Sony use your information?
3.1 To provide services to you
When we use Collected Data to offer our products and services to you, the processing is based on an agreement between you and Sony. In this context, we use Collected Data (as defined in section 2, What information is collected?), to:
- Provide services including enabling you to unlock Xperia devices
- Respond to your customer service and business requests, questions and concerns
The processing is necessary to perform a contract or to take steps, at your request, prior to entering into a contract with you.
3.2 To protect Sony Group Companies and users
Sony may use Collected Data to protect Sony Group Companies’ business interests and legal rights and the interests and legal rights of our users.
This includes the use of Collected Data in connection with legal claims, compliance, regulatory, auditing, investigative purposes (including disclosure of such information in connection with legal proceedings or litigation).
We have a legitimate interest in protecting Sony Group Companies' business interests and legal rights, and the interests and legal rights of our users.
3.3 Compliance with law
Sony may use Collected Data to respond to requests from and, where required, report content to government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws.
When we have a legal obligation under EU/UK laws:
We process Collected Data in order to comply with applicable law and regulations.
When we have a legal obligation under laws outside the EU/UK:
We have a legitimate interest in protecting Sony Group Companies’ business interests and legal rights, and the interests and legal rights of our users.
3.4 Mandatory and Optional Provision of Collected Data
Where we collect the Collected Data to perform a contract with you, or where we have to collect Collected Data by law, provision of this data is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of any requested Collected Data is optional, but not providing information may affect your ability to use the services or use particular aspects of the services if information is needed for those purposes.
4. Who has access to your information?
In general, Sony does not sell, rent or otherwise disclose information about you to third parties without your consent.
However, there are exceptions. Your Collected Data that is communicated to and stored by Sony may be made available to other Sony Group Companies and to third-party contractors as described in this section.
4.1 Sony Group Companies and third-party contractors
Collected Data may be shared with other Sony Group Companies and/or third-party contractors for the purposes of pursuing the activities outlined in section 2 (What information is collected?) and section 3 (How does Sony use your information?) on Sony’s behalf, acting as processors of Sony.
4.2 Our service providers
We regularly use third-party service providers and other Sony Group Companies to provide us with services, such as system testing and website maintenance. When we do this, we sometimes have to share data that we hold with the service providers to get the services to work properly. We ensure that these service providers and other Sony Group Companies have the same safeguards to protect your Collected Data as detailed in this privacy policy.
4.3 Business transfer
If we sell or transfer a portion of or all our business, Collected Data may be transferred by us to the purchasing or acquiring entity as part of the transaction. If we sell or transfer Collected Data to a purchasing or acquiring entity, you will be duly informed.
4.4 Legal purposes
We may retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to government bodies and law enforcement agencies, to investigate complaints made by or against you, prevent fraud, comply with the law, meet a reasonable request from such bodies or protect or defend ourselves, or others, against illegal, criminal or harmful activities.
4.5 Statistics and generic information
We prepare aggregate or de-identified information (including “generic” statistics) for several purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party (such as our partners, industry bodies, the media and/or the general public) or with any other Sony Group Company.
5. Retention of Collected Data
We will only retain Collected Data in accordance with our internal retention policies or for as long as is reasonably necessary for the various purposes set out in section 2 (What information is collected?) and section 3 (How does Sony use your information?), as well as to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of personal information relating to our customers and/or any commercial transactions with them. Should any Collected Data held by us no longer be required by us for any of the purposes set out in sections 2 and 3, we will take reasonable steps to destroy or de-identify any Collected Data after a reasonable period of time has passed.
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us as described in section 10 (Contact information), or your local data protection authority.
6. Privacy rights
6.1 In some countries, you have the following rights with respect to Collected Data Sony processes about you:
- Ask us for a copy of Collected Data
- Ask us to correct, delete or restrict our processing of Collected Data
- Request us to transmit some Collected Data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible
- Object to our processing Collected Data on the basis of our legitimate interests (or those of a third party)
- Where we have asked for your consent, to withdraw consent at any time. If you ask to withdraw your consent, this will not affect any processing which has already taken place at that time.
6.2 You can exercise these rights by contacting us as indicated in section 10 (Contact information) below. These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
6.3 If you have unresolved concerns, you have the right to complain to a data protection authority in the country where you live, work, or where you believe a breach has occurred. Details of EU data protection authorities is available here and the website of the data protection authority of the UK Information Commissioner’s office is here.
7. International transfers of your information
Sony is part of the Sony group, which is a global organization. For the purposes explained in this policy, Collected Data may be transferred to Sony Group Companies (including service providers operating on their behalf) and other third parties in countries that do not have the same level of data protection laws as those in the country where you are located.
For the purposes outlined in section 2 (What information is collected?) and section 3 (How does Sony use your information?), Collected Data may be processed in, stored in and transferred to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan. Your information may be processed and/or accessed by staff—working for us or for one of our service providers—operating outside the EEA and/or your country of residence.
Sony uses a variety of legal mechanisms to help ensure that your rights and protections travel with your information. This is why each of the Sony Group Companies (and their authorized data processors) complies with our internal policy relating to processing of personal information, which complies with the key data protection principles of fair handling of personal information and ensuring adequate level of protection of information.
Please contact us as described in section 10 (Contact information), if you want to receive further information regarding international data transfers.
8. Security
We take several steps to protect your information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, including, where appropriate:
- Limiting access to the information we collect about you (for example, only those of our staff who need your information to carry out our business activities are allowed access)
- Putting in place physical, electronic, and procedural safeguards in line with industry standards
9. Changes
Sony reserves the right to make changes to this Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will inform you of any changes to our Privacy Policy through our Website.
10. Contact information
10.1 If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have in respect of Collected Data, please contact us.
10.2 Sony’s representative in the European Economic Area and Switzerland is Sony Europe B.V. They can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe B.V. at Taurusavenue 16, 2132LS Hoofddorp, the Netherlands.
10.3 Sony’s representative in the UK is the UK branch of Sony Europe B.V. who can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe B.V. (UK branch), The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.
11. Your Privacy Rights/Jurisdiction Specific Notices:
In some jurisdictions, you have certain rights with respect to the Collected Data that Sony holds about you. These may include the right to request access to the Collected Data and/or you may request that Sony corrects, amends, deletes, erases, destroys, blocks/restrict processing and/or use of such Collected Data. You may also object to Sony’s processing of Collected Data. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. If you would like to exercise any rights available to you, please contact us as described in section 10 (Contact information).
(i) Notice to Residents of U.S. States (including but not limited to: VA, CO, CT, MT, IA, DE, UT, TN, TX and OR; but excluding California)
We set forth in our Privacy Policy and Table 1 the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
Consumers in certain states with comprehensive privacy laws may have the following rights:
- Right to Know and Access. The right to confirm whether we are processing personal data about you and to access such data. Residents in certain states may also obtain a list of third parties with whom we have shared personal data.
- Right to Correct. The right to correct inaccurate Personal Data we hold about you.
- Right to Delete. The right to delete the Personal Data provided by you or obtained about you.
- Right to Data Portability: The right to obtain a copy of the Personal Data previously collected by us and, to the extent feasible, in a readily usable format to allow data portability.
- Right to Appeal. If for any reason you would like to appeal a decision made by us relating to your request to exercise privacy rights, you have the right to submit an appeal to us. Please include your full name, the basis for your appeal, and any additional information to consider.
If you would like to submit a request to exercise one of the rights listed above, you can contact us as described in section 10 (Contact information)
- Right to Opt-Out of Targeted Advertising and “Sales”. Sony does not use data to engage in online advertising and analytics practices that may be considered “targeted advertising” or a “sale” of data under applicable state law.
- Right to Opt-Out of Automated Decision Making and Profiling. While some state laws may permit you to opt-out of automated decision making and profiling in furtherance of decisions that produce legal or similarly significant effects, we do not engage in either of these activities at this time.
(ii) Notice to California Residents: California Privacy Notice
This California Privacy Notice is effective as of May 8, 2025.
This California Privacy Notice supplements our Privacy Policy and sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and any implementing regulations adopted thereunder (“CPRA”). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.
California Consumer Rights. Subject to certain exceptions, as a California consumer, you may have the following rights regarding your Personal Information:
- Right to Know. Request information regarding what Personal Information we collect, use, disclose, and sell, including the right to request that we provide you with the categories and /or specific pieces of Personal Information we have collected about you.
- Right to Delete. Request deletion of the Personal Information we collect about you.
- Right to Correct. Request correction of inaccurate Personal Information that we maintain about you.
- “Do Not Sell or Share My Personal Information.” While you may have the right to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), Sony does not sell or use data from the Website to engage in such practices at this time and thus does not provide these rights.
- “Limit the Use and Disclosure of Sensitive Personal Information.” Under the CPRA, a business must provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or does not fall under certain statutory exceptions. Sony does not use or disclose Sensitive Personal Information in connection with the Website and we therefore do not offer this right at this time.
Agents. If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under applicable state law. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We will only use the information you provide in a request to verify your identity.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify your identity, we will not be able to process the request.
Exercising Your Rights.
Right to Know; Right to Delete; Right to Correct.
If you are a California Consumer and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please submit your request at: Data Requests; or you may call us toll-free at 1-833-681-9900.
Data Retention. Sony retains personal information for as long as reasonably necessary for the purposes outlined in this California Privacy Notice. In particular, we retain your personal information as long as is reasonably necessary for the various purposes set out in section 2 and 3. Should any personal information held by us no longer be required by us for any of the purposes set out in sections 2 and 3, we will take reasonable steps to destroy or de-identify any personal information after a reasonable period of time has passed, except as otherwise required by law.
Data Reporting.
Click here to access our data reporting metrics for the previous calendar year.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.
California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will not discriminate against you for exercising your CPRA rights.
Notice of Financial Incentive.
Under California regulations, if we offer certain loyalty or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a “financial incentive”. In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.
Personal Information We Collect & Purposes for Collection.
The Personal Information we collect about you will depend upon how you use the Website. Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by applicable law.
We may have used Personal Information for the business or commercial purposes described in Table 1:
Categories of Personal Information Collected | Purposes for Collection of Personal Information | Who We Share Personal Information With for a Business Purpose | Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising |
|---|---|---|---|
Categories of Personal Information Collected Identifiers: Such as: email address, your name and online identifier such as IP address | Purposes for Collection of Personal Information
| Who We Share Personal Information With for a Business Purpose
| Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising
|
Categories of Personal Information Collected Any categories of personal information described in subdivision (e) of Section 1798.80* Such as: name, contact information and online or device identifiers such as IP address. *Some of this information may also be included in other categories of information | Purposes for Collection of Personal Information
| Who We Share Personal Information With for a Business Purpose
| Third Parties We Sell To, or Share With for Cross Context Behavioral Advertising
|
For more information about our local Sony electronics affiliate’s California privacy practices, please refer to this California-specific information here:Calif. Privacy Notice
Additional Notice to California Residents:
If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to which we may have disclosed, within the past year, personal information pertaining to you and your family for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to SonyElectronicsPrivacy@sony.com, and include your name, email address, mailing address or zip code, and a reference to “Your California Privacy Rights –Open Devices.” We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
(iii) Notice to Nevada Residents
If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. Sony does not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if Sony were to engage in such a sale in the future, you may submit your request in writing to: SonyElectronicsPrivacy@sony.com. Your request must reference “Your Nevada Rights –Open Devices” and include your name, mailing address, zip code, and email address. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. We will respond to valid requests within 60 days.
(iv) Further Information for Residents in Québec, Canada
This notice sets forth disclosures and rights for consumers residing in Québec, Canada regarding their personal information, as required by the Québec’s Data Privacy Law 25. All Sony personnel handling personal information will be subject to a duty of confidentiality and to ensure that all personal information is handled in accordance with standard security measures. By using the Website, you acknowledge and agree that your personal information will be transferred outside of Quebec.
We will only use your personal information for the purposes stated at the point of collection, or as otherwise noted in this privacy policy.
Automated Decision Making.
Sony does not use personal information to render any decisions based exclusively on an automated processing of such information.
Location Tracking.
We may use automated technologies to collect information about your general location, such as your country. However, we do not track your location without your consent.
Consumer Rights.
Subject to certain exceptions, you may have the following rights regarding your personal information:
- Right to Inform/Access. Request to confirm the existence of the personal information, communicate it to you, and allow you to obtain a copy of it.
- Right to Erasure. Request that we remove information we have collected from you.
- Right to Rectify. Request rectification of inaccurate personal information we maintain about you.
- Right to Withdraw/Restrict Processing. Request to withdraw previously provided consent to process your personal information.
You may also ask us to clarify the categories of persons that have access to your personal information and the applicable retention period.
Exercising your rights.
If you are a Quebec resident and wish to exercise your right(s) listed above, please submit your request here: SOCAN Privacy Request Webform; or you may call our toll-free (within Canada) number 1-888-494-7669.
Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.
Our Privacy Officer is in charge of the protection of personal information.
Contact information for SONY’s Privacy Officer.
Sony of Canada ULC,
Attn: Privacy Officer, Law Department
2235 Sheppard Avenue East, Suite 800 Toronto, ON M2J 5B5
Telephone: 1-888-494-7669 (toll free within Canada)
Email: SonyElectronicsPrivacy@sony.com
You may submit a complaint to the Commision d’accès à l’information du Québec (CAI) by visiting: https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.
Last updated: 2026-05