This Privacy Policy is applicable to personally identifiable information (hereinafter referred to as "Personal Data" and detailed below) collected, processed, stored and used by Sony Pictures Networks India Private Limited having its registered office at Interface Building 7, Floor 45, Malad (West), Mumbai – 400064, India ("SPN") either through its owned, controlled and operated website located at http://www.sonyliv.com and/or app named SonyLIV (collectively and individually referred to as "SonyLIV"), in connection with individual Users' ("User", "You", or "Your") access to or use of SonyLIV services. SonyLIV is available on various platforms and devices like mobile phones, tablets, smart televisions, set top boxes and various other devices on which SonyLIV is embedded or otherwise made available.
i. This Privacy Policy should be read in conjunction with the Terms of Use and the Cookie Policy.
ii. By using SonyLIV, You agree to SPN's terms of processing Your Personal Data which You provide to SPN
in accordance with this Privacy Policy.
iii. Please also note that SonyLIV may contain links to third-party websites, platforms or applications
not owned, operated or controlled by SPN. SPN is not responsible for the privacy practices of or for the
Personal Data
processed by such third-party websites, platforms or applications that You may visit.
iv. The Personal Data that such third-party websites, platforms or applications collect directly from
You (for example, payment processing) is subject to such third-party website, platform or application's
privacy practices.
Privacy choices You may make on the third-party websites, platforms or applications will not apply to
SPN or SPN's
processing of the Personal Data as per this Privacy Policy applications.
v. SPN encourages You to be aware of the privacy practices of such other websites, platforms or
applications that You may choose to access from SonyLIV and that may collect Your Personal Data.
The access to complete content and services on SonyLIV is only available on a subscription basis and to Users who are above the age of 18 years. SPN may provide children content or content suitable for individuals below the age of 18 years on SonyLIV but the same shall only be accessible through the profile of a parent or legal guardian who is an adult.
"Personal Data" means any information relating to an identified or identifiable natural person. An
identifiable natural
person is one who can be identified, directly or indirectly, in particular by reference to an identifier
such as a name,
an identification number, location data, an online identifier or to one or more factors specific to the
physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person. When
anonymous information
is directly or indirectly associated with personal data, the resulting information also is treated as
personal data.
To access SonyLIV, SPN requires You to provide Your Personal Data since SPN cannot identify You by a
pseudonym or
through anonymous data. SPN may collect anonymized data from You based on certain activity You perform
on SonyLIV for
analytics and statistical purposes. Such anonymized data will not be associated with Your Personal Data
and will not be
applicable under this Privacy Policy.
SPN may collect the following Personal Data from You:
5.1 Information You Provide to SPN
A. 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:
i. Mobile number
ii. E-mail address
iii. Location (IP, Lat-Long, Country Code)
B. At the time of Account and Profile Creation
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:
i. Name
ii. Profile name
C. 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
including but not limited to:
i. Session ID
ii. IP address
iii. Device ID
iv. Order ID
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 or postings on SonyLIV to SPN, 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 id, 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.
A. 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:
i. Content viewed
ii. Types of content viewed
iii. Date and time of view
iv. Content added to ‘My List'
v. Number of times You visited SonyLIV in a specific duration of time
vi. Number of page views
vii. Type of computer operating system including the type of internet browser and internet
service provider.
viii. Quality of content streaming at the time of video playout
ix. Number of concurrent sessions
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.
B. 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 address for the following purposes:
i. Determining Your geographic location, and provide content available in the said geographic
location;
ii. Processing Your registration and payments;
iii. To enable processing of coupons or vouchers for subscription offers; and
iv. To detect and monitor any fraudulent activity.
C. SPN may collect unique identifier 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").
If collected, these Device Identifiers will be used for the following purposes:
i. Providing the User with SonyLIV content and services based on the User's location;
ii. To enable processing of coupons/vouchers for subscription offers;
iii. Identifying the User when he/she accesses or downloads SonyLIV; and
iv. Measuring the User behavior in terms of user interface, clicks, response etc.
D. SPN may also have 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:
i. Clevertap ID to provide You with push notifications;
ii. CP Customer ID to identify unique user;
iii. GA ID to help SPN derive analytical insights;
iv. Charged ID for transaction purposes;
v. Profile ID assigned to each profile created by You for mapping the Content; and
vi. Order ID for unique user making a subscription on SonyLIV.
E. 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 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 in nature. For
more information
about the cookies SPN uses, please refer to SPN's Cookie Policy.
F. 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.
G. 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 the EU, EEA and UK 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. You will be asked to
provide Your consent
for such storage and transfer of Your Personal Data to the third parties which may or may not be located
within the
territory from which You are accessing SonyLIV.
H. 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:
i. Microphone
ii. Gallery
iii. Phone/SMS
iv. Camera
v. In APP purchases
vi. Bluetooth
SPN will seek Your consent before using any permissions which are not mandatory in nature. The use
of microphone and
phone/SMS are essential to use audio for audio searching and sending an OTP (one -time-password) for
Your authentication
purposes for registration and/or subscription of SonyLIV, respectively.
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:
i. To perform analytics and conduct customer research, to determine Your interest, for identifying
content that generate
sales and to analyze traffic patterns;
ii. To study traffic patterns to improve website performance, to customize user experience, and to
better match users'
interests and preferences;
iii. Keep track of preferences You specify while You are using SonyLIV content or services;
iv. Capturing video playback features and working on SonyLIV;
v. Capturing user behavior for measuring quality specifications of SonyLIV;
vi. Keeping track of multiple profiles created by You.
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 to
familiarize with the
terms of use and privacy policies of the respective third-party payment gateway service providers before
using such
service. You hereby agree and acknowledge that SPN shall not be liable and in no way, be held
responsible for any losses
whatsoever, whether direct, indirect, incidental or consequential, including without limitation any
losses due to online
fraud arising from Your use of such payment gateways. In case of any issues or complaints with respect
to the processing
of Your payments in relation to SonyLIV, You may file a complaint with the concerned third-party payment
gateways
directly for redressal.
In case of recurring payments, the amount will be automatically deducted from the bank account, debit or
credit card the
details of which You may have provided. The subscription amount will automatically get deducted until
You otherwise opt
to cancel the auto debit by visiting SonyLIV and cancelling subscription in Your Account.
SPN never asks for password, financial details or any additional personal data without highlighting the
purpose of
collecting the same.
SPN may use the Personal Data collected for the following purposes:
i. process Your registration on SonyLIV;
ii. determine Your geographic location and provide content available in the said territory;
iii. enable You to visit SonyLIV and enjoy more seamless visits to SonyLIV;
iv. enable You to use and receive the services offered on SonyLIV including e-mail
communications informing You about the services and content provided through SonyLIV;
v. enable processing of coupons or vouchers for subscription
vi. contact You about Your Account and in connection with any services or content support,
feedback through SonyLIV;
vii. improve and enhance SonyLIV usage experience according to Your preferences;
viii. increasing security measures to keep Your data safe by preventing, detecting and
investigating potentially prohibited or
illegal activities;
ix. support security measures, such as requiring re-login into SonyLIV after a certain amount of
time has elapsed;
x. analyzing the User behavior to generate analytical insights and provide enhanced SonyLIV
services;
xi. creating custom reports on payment/redemption against each device make, model, serial
number;
xii. notify You about changes in the services offered by SonyLIV or changes in this Privacy
Policy; and
xiii. other purposes specifically disclosed to You prior to the collection of Your Personal Data
or otherwise with Your
consent.
If SPN wishes to collect and process Your Personal Data for purposes other than those mentioned
above, SPN shall seek a
specific consent from You prior to collecting and processing Your Personal Data for such additional
purposes unless this
falls within legitimate business interest for processing as explained in paragraph 7 below.
SPN processes Your Personal Data for the purposes detailed hereunder, basis the following lawful basis under GDPR: (i) obtaining explicit consent from You for processing Your Personal Data; (ii) where it is necessary for SPN to undertake its legal obligations; (iii) SPN's exercise of its rights under a contract with You; or (iv) processing of Personal Data for legitimate interests where processing is not necessary to meet contractual obligations, but is necessary to provide You with services and content of SonyLIV.
SPN may share Personal Data with the following parties:
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.
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.
SPN may transfer and disclose Your Personal Data to:
i. 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;
ii. to government and regulatory authorities at their request or order;
iii. to verify or enforce SonyLIV's Privacy Policy, Terms of Use, Cookie Policy or other
applicable policies;
iv. to protect the rights, property, safety, or security of third parties, users or the public
or in response to a similar
emergency.
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.
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.
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:
i. 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;
ii. retention and use of Your Personal Data as necessary for SPN's legitimate business
interests, such as fraud detection
and prevention and enhancing safety;
iii. 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;
iv. 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
v. 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:
i. 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
ii. 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.
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. To send a request for any of the above-mentioned purposes, kindly send an e-mail to SPN's DPO at dpo@setindia.com. SPN may take up to 30 (thirty) days from the date of receipt of request to complete Your requests. However, if the nature of Your request requires significant effort or is time consuming in terms of locating the date or in terms of quantity of data that it relates to, then SPN may ask for an extension of a further 60 (sixty) days by giving a prior notice to You with the reason for the extension.
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. 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 SonyLIV'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.
SonyLIV may, in future, make available content that will apply or be directed at persons less than 18
years of age and
such content may be accessed only by via the profile of the parents or legal guardians of the minors.
SPN does not
intend to collect or knowingly collect Personal Data from minors. SPN does not knowingly permit any
person who is under
18 years of age to register with SonyLIV or to provide any other Personal Data. Parents or the legal
guardians are
advised to monitor the minor's use of SonyLIV, who are accessing the services and content of SonyLIV
through the
profiles of such parents or legal guardians. It shall be the parent's or legal guardian's responsibility
to decide
whether or not the use of or access to SonyLIV is suitable for their minor and to monitor the Personal
Data of the
minor, required for his or her use of or access to SonyLIV and the consents for the same. SonyLIV does
provide a
functionality of Parental Control for such purposes where You can lock Your profile with the help of a
password.
In the event SPN collects Personal Data of minors, SPN will obtain a parental consent from the minor's
parent or legal
guardian prior to collection and processing of such Personal Data.
i. SPN respects Your privacy and is committed to protecting the personally identifiable information
You provide when You
use or access SonyLIV services. SPN takes commercially reasonable and appropriate precautions to
protect Your Personal
Data from unauthorized disclosure and security breaches.
ii. You understand that the services offered by SonyLIV are on a subscription basis. SPN may send
SMS, e-mail or other
notification prior to expiry of Your subscription services to notify you about the last date of Your
subscription. For
auto renewal subscription, You may receive SMS, E-mail or notification from SPN or SPN's authorized
vendor notifying You
about the renewal of your subscription pack depending upon the subscription duration and payment
preferences You may
have chosen at the time of registration and creation of Your Account.
iii. It is important to let You know that electronic data can be intercepted, corrupted, lost or
destroyed. SPN cannot
guarantee or warrant the security of any data and consequently Your use of SonyLIV is at Your own
risk. SPN is however
continuously implementing and updating administrative, technical and physical security measures to
help protect Your
Personal Data against unauthorized access, loss, destruction, corruption or alteration.
iv. If You know or have reason to believe that Your account credentials have been lost, stolen,
altered, or otherwise
compromised or there has been an actual or suspected unauthorized use of Your account, please
contact Data Protection
Officer (DPO) by email at dpo@setindia.com.
SPN will update this Privacy Policy from time to time in response to changing legal, regulatory, business or operational requirements or when there is a change or update in the services offered on SonyLIV. SPN will provide notice of any such changes to the Privacy Policy, including when such changes will take effect, in accordance with the applicable law. Your continued use of SonyLIV after any such updates to the Privacy Policy will constitute acknowledgement and acceptance of those changes. If You do not wish to acknowledge or accept any updates to this Privacy Policy, You may cancel Your Account, subscription and use of SonyLIV.
i. Processing, usage and storage of Personal Data
ii. This Privacy Policy
iii. Exercise of Your rights as a data subject as provided under the applicable law
iv. Grievances with respect to processing, usage and storage of Your Personal Data
v. General enquiry/ clarification in relation to the Personal Data
vi. Suggestions/ feedback related to Privacy Policy and privacy practices
If You contact SPN with a privacy complaint, it will be assessed with the aim of resolving the issue
in a timely and
effective manner. Please note that if You contact SPN to assist You in this regard, for Your safety
and SonyLIV's, SPN
may need to authenticate Your identity before fulfilling Your request.
In case You require technical support (like subscription related, app functioning related, technical
related, payment
related, etc.), You may write to SPN at prioritysupport@sonyliv.com.
SPN will only use Your email id for customer interaction and communication. After your query is
resolved, SPN will not
share with You information about its services including the SonyLIV, either through mailers or any
other form of
communication for which You dont provide consent to SPN.
You may also reach out to SPN's EU Representative, Shalin Patel at Shalin_Patel@spe.sony.com, if You
have questions or
concerns regarding SPN's privacy practices.
Last Updated: 10th August, 2021.