5.1. Information that SPN mandatorily collects for the SonyLIV app to function and offer services:

1. At the time of Registration and Sign Up

To use SonyLIV and the services it offers, Users must register and create an account ("Account"). Creating the Account may require the User to provide the following Personal Data associated with the User, including but not limited to:

1. Mobile number
2. E-mail address
3. Location (IP, Lat-Long, Country Code)
2. At the time of Account and Profile Creation
1. Name
2. Profile name
3. At the time of using coupon codes

You may also subscribe to SonyLIV by using an activation or subscription codes or coupon provided by SPN or its commercial associates authorized to issue codes or coupons. SPN may store details related to codes or coupons You use and associated with it the Order ID, IP Address and Device ID.

4. At the time of watching content on SonyLIV
1. Session ID created when You login in and out of the SonyLIV application or website;
2. IP address
3. Device ID
4. Order ID
5. Advertising ID
5. At the time of making payments
1. Residential address (including city/state/province) along with postal code.

5.2. Additional Personal Data provided by You Voluntarily

If You send any correspondences, such as emails or letters including data subject requests to SPN, or if other users or third parties send Personal Data about Your activities on SonyLIV, then SPN may collect and store such Personal Data. SPN may collect additional Personal Data at other times, including but not limited to, when You provide feedback, when You change Your content or email preferences etc. This Personal Data includes the information You may share with SPN during such correspondence like Your name, e-mail address, mobile number, city, country, etc.

The additional Personal Data mentioned above is collected solely for the purpose of communicating with the User regarding the SonyLIV services, processing the feedback received, and conducting surveys to implement suggestions, processing and implementing change requests, data subject requests and enriching the overall user experience. Users will be asked to provide their consent in case the above-mentioned Personal Data is processed for any purpose other than those detailed above.

5.3. Personal Data automatically collected while browsing or navigating through SonyLIV

1. Throughout Your use of SonyLIV, SPN may use a variety of technologies that automatically or passively collect Personal Data with respect to how SonyLIV is accessed and used by You ("Usage Information").

Usage Information may consist, inter alia, of the following data about Your visit, usage of services and consumption of content on SonyLIV:

1. Content viewed
2. Types of content viewed
3. Date and time of view
4. Content added to ‘My List’
5. Number of times You visited SonyLIV in a specific duration of time
6. Number of page views
7. Type of computer operating system including the type of internet browser and internet service provider
8. Quality of content streaming at the time of video playout
9. Number of concurrent sessions
10. Logs and bandwidth monitoring for assessing Sony LIV’s site performance

Usage Information is generally of a nature which is non-identifiable of a natural person (for example aggregate analytics). However, in order to process such Usage Information and to make it feasible for SPN’s legitimate business interests, SPN may associate the Usage Information with other information collected from You and such combination may be treated as Personal Data.

2. SPN may also collect Your IP address from Your computer, mobile or any other device on which You access SonyLIV. An “IP address” is an identifying number for network hardware connected to a network. It helps to recognize the location of the User.

SPN uses IP addresses for the following purposes:

1. Determining Your geographic location, and providing content available in the said geographic location;
2. Processing Your registration and payments;
3. To enable processing of coupons or vouchers for subscription offers; and
4. To detect and monitor any fraudulent activity.
3. SPN may collect unique identifiers from Your device. It is a number that is automatically assigned to Your device when You access SonyLIV, use its services and stream content therefrom, and SPN’s systems will identify Your device by this number ("Device Identifier(s)").

If collected, these Device Identifiers will be used for the following purposes:

1. Providing the User with SonyLIV content and services based on the User’s location;
2. To enable processing of coupons/vouchers for subscription offers;
3. Identifying the User when he/she accesses or downloads SonyLIV; and
4. Measuring the User behavior in terms of user interface, clicks, response etc.
4. SPN may also have certain integrations of SonyLIV with some third-party service providers who may, on SPN’s instructions, collect the Device Identifier or create their own unique Device Identifier including but not limited to:
1. Clevertap ID to provide You with push notifications;
2. CP Customer ID to identify unique user;
3. GA ID to help SPN derive analytical insights;
4. Charged ID for transaction purposes;
5. Profile ID assigned to each profile created by You for mapping the Content; and
6. Order ID for the unique user making a subscription on SonyLIV.
5. Cookies

To improve Your experience on SonyLIV, SPN collects, uses and stores cookies. Cookies are files that web servers place on Your device to provide You with a seamless interaction with the web and application platforms. Some of these cookies are mandatory for the functioning of SonyLIV while some cookies are used to track Your behavior on SonyLIV for an enhanced experience. SPN will seek Your consent before using any cookies which are not mandatory.

For more information about the cookies SPN uses, please refer to SPN’s Cookie Policy.

6. SPN also uses asynchronous technology for the purpose of building web applications and providing optimized performance of SonyLIV in terms of fetching, loading and refreshing the content. SPN does not pass any Usage Information or Personal Data to any of these technology providers through use of their technology or otherwise.
7. For the smooth functioning of SonyLIV, SPN may also use an analytics service provider. Such service providers may use an analytics tool. Analytics tools use cookies, text files, SDKs, APIs, etc. that are stored on Your device and allow an analysis of Your use of SonyLIV. The information generated by the cookies about Your use of SonyLIV, including the IP address, may be transferred to and stored on a server of such analytics service provider engaged by SPN, which may not be located within your country of residence and who may use such information, to analyze Your use of SonyLIV, to create reports about the activities and to provide further services associated with the use of SonyLIV to SPN. Furthermore, it may transfer such information generated to third parties, to the extent legally required or permitted or if such third parties process the information on behalf of the analytics service providers.
8. In-App Permissions

To provide You with certain features and to improve Your experience on the application of SonyLIV, SPN asks You for the following in-app permissions:

1. Gallery / Files & Media / Storage
2. Camera
3. Bluetooth
4. Notifications
5. Local network (only for iOS for casting)

SPN will seek Your consent before using any permissions which are not mandatory in nature.

5.4. Inferred information through usage and log data

SPN may track certain information about You, in an anonymized manner, based upon Your behavior while using SonyLIV for below mentioned purposes of analytics and statistical insights:

1. To perform analytics and conduct customer research, to determine Your interest, to identify content that generates sales and to analyze traffic patterns;
2. To study traffic patterns to improve website performance, to customize user experience, and to better match users' interests and preferences;
3. Keep track of preferences You specify while You are using SonyLIV content or services;
4. Capturing video playback features and working on SonyLIV;
5. Capturing user behavior for measuring quality specifications of SonyLIV;
6. Keeping track of multiple profiles created by You; and
7. to track the stability of SonyLIV and fix any bugs for enhanced performance of SonyLIV.

5.5. Third-Party Payment Gateway – Financial Information

SonyLIV uses third-party payment gateways to process payments made on SonyLIV. SPN will provide You with a confirmation of having received payments against Your subscription Account, only once SPN receives such confirmation from the concerned third-party payment gateway service providers. The third-party payment gateway service providers may require certain financial information including Your credit card, debit card, mobile number or other bank account information. Other than providing a confirmation upon receipt of payment against a subscription Account, SPN disclaims all liabilities in relation to Your payment processing by such third-party payment gateway service providers and the collection and processing of any Personal Data provided by You to such third-party payment gateway service providers. While using such third-party payment gateways to make payments to SPN, You will be required to accept the terms of use and privacy policies of such third-party payment gateway service providers. SPN requests You familiarize yourself with the terms of use and privacy policies of the respective third-party payment gateway service providers before using such service.
1. SPN never asks for passwords, financial details or any additional personal data without highlighting the purpose of collecting the same [through the relevant privacy policy].

8.1. Service providers providing services on SPN’s behalf

SPN may, from time to time, employ third-party service providers to perform certain functions on SPN’s behalf, such as hosting or operation of SonyLIV, hosting the Personal Data, e-mails, messages or other communications, and providing data analysis services etc. within or outside Your country. Wherever Your Personal Data is transferred, stored or processed, SPN will take reasonable steps to safeguard the privacy of Your Personal Data. Any Personal Data shall be disclosed to such third-party service providers only after ensuring contractual protection of Your Personal Data, including that such third-party service providers implement adequate technical measures to safeguard Your Personal Data. These third-party service providers are prohibited from using Your Personal Data for purposes other than those specified in Paragraph 6 above or required by law. Additionally, if You have any queries or questions regarding collection, use, disclosure or storage of Personal Data by service providers outside United States of America, on behalf of SPN, You can reach out to our DPO at dpo@setindia.com

8.2. Affiliates of SPN and Business Transfers

SPN operates globally and it may transfer Your Personal Data to SPN’s affiliated companies primarily for business and operational purposes.

SPN or any of its businesses, including SonyLIV, may be acquired or merged or de-merged or spun off or may be subject to any other transactions wherein SPN may no longer remain the controller or processor of Your Personal Data. In such cases, where any such transaction takes place which covers Your Personal Data, Your Personal Data shall be transferred as part of such transaction. Such transfer of Your Personal Data will without any further notice to the Users and by using SonyLIV, You hereby acknowledge and agree that this Privacy Policy will serve as notice enough for any such transfer.

8.3. Disclosures required under laws and regulations

SPN may transfer and disclose Your Personal Data to:

1. comply with a requirement or an obligation under a law or regulation when SPN in good faith believes that such disclosure is required under such law or regulation;
2. government and regulatory authorities at their request or order;/li>
3. verify or enforce SonyLIV's Privacy Policy, Terms of Use, Cookie Policy or other applicable policies;
4. protect the rights, property, safety, or security of third parties, users or the public or in response to a similar emergency.

The aforesaid disclosures may be carried out by SPN without notice to You.

8.4. No sale of Personal Data

SPN does not ‘sell’ Personal Data of its Users.

8.5. Non – discrimination

SPN will not discriminate against any consumer for exercising their rights.

9.1. Accessing and rectifying your Personal Data

1. When You use SonyLIV, SPN makes reasonable efforts to provide You with Your right to access Your Personal Data and further upholding the accuracy of the Personal Data by providing You with a fairly simple functionality within SonyLIV for rectifying Your Personal Data You may have provided. For example, You can easily access or edit Your Account information (Name, Profile Name) through the “MY ACCOUNT” section available on SonyLIV.
2. If You choose to authorize any individual to make a request for access and rectification of Your Personal Data on Your behalf, in such a situation SPN will require You or the individual making the request on Your behalf, to submit proof of such authorization prior to accepting such any request for access or rectification. Kindly note, that SPN reserves its rights to decline any such request made for access or rectification of Personal Data on behalf of another individual, should SPN not be satisfied with the proof of authorization submitted in this regard in accordance with applicable law.
3. If You are a User based in California, You have the right to limit our use and disclosure of sensitive Personal Data to uses that are reasonably necessary to perform services, provide goods to you, or as otherwise permitted by the California Consumer Privacy Act.

9.2. Data Portability

You may request copies, in a structured, commonly used, and machine-readable format, of the Personal Data that You provided to SPN, wherever feasible. Alternatively, You may request for Your Personal Data to be transmitted to another service provider (where technically feasible) directly by SPN.

9.3. Data Retention and Erasure

SPN retains Your Personal Data for legitimate business interests and until SPN requires such Personal Data for the purposes for which the same has been collected as specified in Paragraphs 6 and 7. SPN may also need to retain Your Personal Data for SPN to comply with legal obligations as specified in Paragraph 8. If You no longer want SPN to use Your Personal Data, then You can request that SPN erases Your Personal Data. Do note that if You request for the erasure of Your Personal Data, SPN may retain some of the Personal Data as may be required for the following purposes and as permitted by law:

1. a unique identifier used for registration purposes such as e-mail or mobile number to detect for any fraudulent activity such as obtaining free consecutive trial offers;
2. retention and use of Your Personal Data as necessary for SPN’s legitimate business interests, such as fraud detection and prevention and enhancing safety;
3. retention and use of Your Personal Data to the extent necessary to comply with SPN’s legal obligations (specified above). For example, SPN may keep some of Your Personal Data for tax, legal reporting and auditing obligations;
4. Personal Data You share with SPN (e.g. comments, complaints, feedback etc.) maybe retained for legitimate purposes, even after Your Account or subscription is cancelled, suspended, terminated or withdrawn; and
5. Because of the way SPN maintains certain services, after You delete Your Personal Data, residual copies of such Personal Data, it may take some time before these are deleted from SPN’s active servers and may remain in SPN’s backup systems.

You should be aware that it may not be possible to completely remove or delete all Your Personal Data from SPN’s databases to effect any opt-out preferences You have made due to technical concerns with data backup and contingency support.

Your request for deletion or modification of Your Personal Data shall be subject to the following:

1. where You have shared Your Personal Data, that You wish to request for deletion or modification, directly with a third party vendor, You shall request such third-party vendor for deletion or modification of Your Personal Data. SPN shall not be responsible for the deletion or modification of such Personal Data as a data controller; and
2. in case the Personal Data that You request for deletion or modification has been collected and used only by SPN and SPN’s appointed and contracted processors and contractors, SPN shall be responsible for the deletion or modification of the Personal Data requested subject to the data retention conditions stipulated in this Privacy Policy.

Do note that if You have multiple accounts with SonyLIV, then You will have to raise separate requests for deletion or modification of Your Personal Data for each of the Accounts, along with the associated email IDs or phone numbers or provide SPN with any unique identifiers as may be required for identifying Your Personal Data in SPN’s systems.

9.4. Objection and Restriction of Processing

Where there is a lawful basis for processing Your Personal Data and such processing falls within SPN’s legitimate interest like, without limitation, Device ID, IP Address, geo-location, User ID, or where You have reasons to believe that the Personal Data being processed by SPN is inaccurate, unlawful or is no longer required to be processed by SPN under any lawful basis, You may, at any time, ask SPN to restrict or object the processing of Your Personal Data.

9.5. Opting Out
You can opt-out of receiving general marketing emails or push notifications by following the step-by-step process detailed in our FAQ section. Alternatively, you can opt out by following the opt-out or unsubscribe instructions in the message or by contacting us at prioritysupport@sonyliv.com. Currently, SPN does not engage in cross-context behavioral advertising or targeted advertising. If you would like to opt out of collection of non-mandatory cookies, you will need to click here and opt out of cookies by using the cookie settings page for SonyLIV.

To send a request for any of the above-mentioned purposes, kindly send an e-mail to SPN’s DPO at dpo@setindia.com or write to us sent by facsimile transmission, to the fax telephone number +91 (22) 6640 7557. SPN shall process your request within 45 (forty-five) days from the date of receipt of request to complete Your requests. Depending on the complexities involved, SPN may seek an extension of a further 45 (forty-five) days by giving a prior notice to You with the reason for the extension. If SPN denies your request, SPN will notify you and provide our reasons for the denial and instructions regarding the rights you may have under applicable laws to appeal the decision. If the appeal is denied, SPN will notify you of your rights under applicable laws to submit a complaint.

9.6. SPN shall not charge You for fulfilling any of the above requests. However, if the fulfilment of any such request leads to certain costs being incurred by SPN, then SPN will notify You prior to processing such request.

9.7. SPN advises the Users to identify themselves in their requests to the DPO for exercising any of their rights with respect to their Personal Data. SPN may not be able to process any requests made in the event the User fails to identify themselves or if SPN is unable to authenticate such a User. In accordance with applicable law, SPN may also decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate effort, jeopardizing the privacy of others, or would be extremely impractical or for which access is not otherwise required.

9.8. Please be aware that if You do not allow SPN to collect Personal Data from You, SPN may not be able to deliver certain experiences, features and services to You, and some of Sony LIV’s services may not be able to take account of Your interests and preferences. If collection of Personal Data is mandatory, SPN shall inform You at the point of collection so that You can make an informed decision whether You wish to allow the processing of such Personal Data.