Privacy Policy

 

Introduction

Welcome to Alpha Universe Middle East & Africa.

We at Sony Middle East and Africa FZE including our affiliates (referred herein as “Sony”, “we”, “us”, “our”) care deeply about yourright to privacy and strive to protect your Personal Information. This Privacy Policy will inform you as to what Personal Information we collect from you when you visit this Website, the way we use and dispose of it and also the way you can control your Personal Information.

By using the Website, you consent to the data practices described in this Privacy Policy as well as our Terms and Conditions of Use. If you do not agree to any part of this Privacy Policy, then you should stop accessing the Website. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or Processing Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

In order to serve you better, we may update this Privacy Policy from time to time. We encourage you to periodically review this web page so as to be informed of any changes to this Privacy Policy.

Please also use the Glossary (section 6 below) to understand the meaning of some of the terms used in this Privacy Policy.

1 Important information and who we are

1.1 Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and Process your Personal Information through your use of this Website, including any information you may provide through this Website when you register your profile on this Website, or when you register for a workshop or seminar.

1.2 Controller

Sony is the Controller and responsible for your Personal Information.

We have appointed a privacy officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the privacy officer using the details set out below.

1.3 Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy officer in the following ways:

Full name of legal entity: Sony Middle East and Africa FZE

Email address: [email protected]

Postal address: P.O. Box 16871, Jebel Ali Free Zone, Dubai, United Arab Emirates – for the attention of “Personal Information Management Office”.

Telephone number: +971 (4) 8815488.

You have the right to make a complaint at any time to the Information Regulator, the South African supervisory authority for Personal Information protection issues (http://www.justice.gov.za/inforeg/). Please note that, as the Protection of Personal Information Act, 2013 (POPI) is not yet in force, the Information Regulator does not have the power to enforce compliance in terms of POPI. We would, however, appreciate the chance to deal with your concerns before you approach the Information Regulator so please contact us in the first instance.

1.4 Your duty to inform us of changes

It is important that the Personal Information we hold about you is accurate and current. If your Personal Information changes during your relationship with us, please make sure to update your Personal Information by logging in to your account. If this option is not available to you, please contact us using the details indicated above.

1.5 Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

2. Data we collect from you

2.1 General

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

• Identity Information includes first name, last name, nationality, username or similar identifier, age range, and gender.

• Contact Information includes email address, current address and telephone numbers.

• Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.

• Profile Information includes your username and password, your photo equipment (if any), seminars/workshop you wish to attend and other similar information,feedback and survey responses.

• Usage Information includes information about how you use our website, products and services.

• Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Information such as statistical or demographic data for any purpose, where such Aggregated Information has been generated by a third party like Google Analytics. Aggregated Information could be derived from your Personal Information but is not considered Personal Information in law as this information will not directly or indirectly reveal your identity. For example, we may use Aggregated Information based on your Usage Information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

We do not collect any Special Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The aforementioned information will be kept on file in our dedicated secure servers and processed in accordance with this Privacy Policy.

2.2 If you fail to provide Personal Information

Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a platform to share your media on our Website). In this case, we may have to cancel your registration on our Website but we will notify you if this is the case at the time.

3. How is your Personal Information collected?

We use different methods to collect Personal Information from and about you including through:

3.1 Direct interactions

You may give us your Identity, Contact and Profile Information by filling in forms or by corresponding with us through this Website or by e-mail or otherwise. This includes Personal Information you provide when you register a profile on our Website, or when you give us feedback or otherwise contact us.

3.2 Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Information about you if you visit other websites employing our cookies. Please see section 3.4 below for more information about how we use Cookies.

3.3 Third parties or publicly available sources

We will receive Personal Information about you from various third parties as set out below:

• Technical Information from analytics providers, advertising networksand/or search information providers.

• Identity and Contact Information from publicly available sources.

3.4 Cookies

Cookies and similar technology are the elements of data that can be sent to your browser. Cookies will not always contain Personal Information. Your browser may store Cookies on your system based on the preferences you have set on your browser. Cookies, for example, gather information about your operating system including, but not limited to, browser type, and IP address.

On our Website we occasionally use Cookies to enhance the information and services provided, and to make navigating the Website more convenient. The Website does not use Cookies to obtain information that would allow it to identify you except in cases where you have agreed to provide such information beforehand.

You have the option to configure your internet browser to notify you when you receive a Cookie, giving you the chance to decide whether to accept it or delete it, if the Cookie has already been set. Further, you have the option to block all Cookies. To learn more about how to reject Cookies go to the help menu within your internet browser.If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.

Please note, however, that if you refuse or otherwise block Cookies you may not be able to use all of the functionality available on the Website.

3.5 Children under 18

The Website is not intended for use by children under the age of 18, and such use is prohibited by our Terms and Conditions of Use. We do not knowingly collect Personal Information from children under 18. If you become aware that a child has provided us with Personal Information, please contact us.

4. Use of your Personal Information

4.1 Service Provision

Sony collects and uses Personal Information to provide you the service you have requested, including but not limited to register you for workshops, seminars, photo walks and other activities organized by or on behalf of Sony.

4.2 Purposes for which we will use your Personal Information

We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may Process your Personal Information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal basis we are relying on to Process your Personal Information where more than one basis has been set out in the table below.

Purpose/Activity	Type of Personal Information	Lawful basis for Processing including basis of legitimate interest
To register you on our Website	• Identity • Contact • Profile	a) Performance of a contract with you; or b) Consent
To register you for a workshop, seminar or photo walks or other activities organised by us or third parties	• Identity • Contact • Profile	a) Performance of a contract with you; or b) Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey	• Identity • Contact • Profile • Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	• Identity • Contact • Profile • Usage • Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	• Identity • Contact • Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	• Identity • Contact • Profile • Usage • Marketing and Communications • Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	• Technical • Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	• Identity • Contact • Technical • Usage • Profile • Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

4.3 Marketing

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.

4.4 Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us from us and you have not opted out of receiving that marketing.

4.5 Third-party marketing

We will get your express opt-in consent before we share your Personal Information with any third party for marketing purposes.

4.6 Opting out

Please use any of the following options to ask us or third parties to stop sending you marketing messages at any time:

• logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences;

• by following the opt-out links on any marketing message sent to you; or

• by contacting us at any time.

4.7 Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Retention and disclosure of Personal Information

5.1 General

We will only retain Personal Information for as long as is reasonably necessary for the various purposes set out in this Privacy Policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information.

Sony may disclose your Personal Information to third parties when:we have contracted any part of the management and operation of this Website to a third party vendor (for example, to host Personal Information, or store back-ups of Personal Information); we are required to or we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this Privacy Policy or our other policies or agreements; to protect our or our users’ rights, property or safety; to protect our users from fraudulent, abusive, or unlawful use of the Website; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires or justifies disclosure of Personal Information.

5.2 Retention period

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for or subsequently Processed, unless: the retention of the information is required or authorised by any legal or regulatory requirements; we reasonably require the information for lawful purposes relating to one of our functions or activities (for example in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you);the retention of the information is required by a contract entered into between us; or you consent to such retention of information.

We may also retain your Personal Information for a longer period for historical, statistical or research purposes only where we have implemented appropriate safeguards against your information being used for any other purpose (for example, by anonymising the information so that it can no longer be associated with you). To determine the appropriate retention period for Personal Information, we consider: the amount, nature and sensitivity of the Personal Information; the potential risk of harm from unauthorised use or disclosure of your Personal Information; the purposes for which we Process your Personal Information; and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.

6. Cross-border transfers of Personal Information

6.1 Sony Group

We share your Personal Information within the Sony Group. This will involve transferring your Personal Information outside your particular country.

6.2 Third parties

Many of our external third parties may be based outside your country so their Processing of your Personal Information will involve a transfer of information outside your country.

6.3 Use of this Website

By using our Website, you agree to not being notified of details regarding the level of protection afforded to your Personal Information in the relevant country/countries.

7. Security

7.1 Measures

We have put in place appropriate security measures to prevent your Personal Information from being lost, damaged, destroyed in an unauthorised way or accessed in an unauthorised way. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only Process your Personal Information on our instructions and they are subject to a duty of confidentiality.

7.2 Cyber incident response

We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Right to control your Personal Information

8.1 Rights

Under certain circumstances, you have the following rights under Applicable Data Protection Laws in relation to your Personal Information:

• Notification that your Personal Information is being collected. When your Personal Information is collected, you have the right to be informed that your information is collected and where the information is not collected from you, you have the right to be informed of the source from whom/which it is collected.

• Notification of security compromises. Where reasonable grounds exist for us to believe that your Personal Information has been accessed or acquired by an unauthorised person, you have the right to be notified.

• Request access to your Personal Information. You have the right to confirm, free of charge, whether or not we hold any of your Personal Information, and to the extent that we do hold your information, to request a copy or description of that record free of charge. You will be required to provide adequate proof of your identity so that we can confirm your identity and ensure your right to access your Personal Information. We may need to request other specific information from you to help us process your request. This is a security measure to ensure that Personal Informationis not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

• Request correction of your Personal Information. You have the right to request us to correct or delete your Personal Informationwhich we have in our possession, where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully.

• Request destruction or deletion of your Personal Information. You have the right to ask us to delete or remove your Personal Informationwhere there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Informationwhere you have successfully exercised your right to object to processing (see below), where we may have Processed your information unlawfully or where we are required to erase your Personal Informationto comply with the law. Note, however, that we may not always be able to comply with your request of destruction or deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to Processing of your Personal Information. You have the right to object to our Processing of your Personal Informationwhere we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to Processing on this ground. You also have the right to object where we are Processing your Personal Informationfor direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to Process your information which override your right to object to Processing.

• Request restriction of Processing your Personal Information. This enables you to ask us to suspend the Processing of your Personal Informationin the following scenarios:

 if you want us to establish the information’s accuracy;

 where we no longer need the information for the purpose for which the information was initially collected but we need it for purposes of proof;

 where our use of the information is unlawful but you do not want us to erase it;

 if you want us to transmit your Personal Informationinto another automated processing system.

• Withdraw consent. You have the right to withdraw your consent at any time where we are relying on consent to Process your Personal Information. However, this will not affect the lawfulness of any Processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Submit a complaint to the Information Regulator. You have the right to submit a complaint to the Information Regulator regarding an alleged interference with the protection of your Personal Information. However, please note that until POPI is in force, the Information Regulator does not have the power to enforce your protection under POPI.

• Institute civil proceedings. You have the right to institute civil proceedings regarding an alleged interference with the protection of your Personal Information. However, please note that until POPI is in force, the Information Regulator does not have the power to enforce your protection under POPI.

If you wish to exercise any of the rights set out above, please contact us.

8.2 Time limit to respond

We try to respond to all legitimate requests within a month from the date of receipt of your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Definitions

• Applicable Data Protection Laws means all laws and regulations applicable to the Processing of your Personal Information under this Privacy Policy and includes POPI;

• Controllermeans the entity that decides how and why Personal Information is Processed;

• Cookie means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

• Information Officer has the meaning as provided in terms of sections 55 and 56 of POPI;

• Information Regulator means the regulatory authority appointed in terms of section 39 of POPI;

• Personal Information means information about an individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual, and where applicable, information relating to an identifiable, existing juristic person;

• POPI means the Protection of Personal Information Act 4 of 2013;

• Process means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including:

– the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;

– dissemination by means of transmission, distribution or making available in any other form; or

– merging, linking, as well as restriction, degradation, erasure or destruction of information;

• Special Personal Information means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under Applicable Data Protection Laws.