Sony Interactive Entertainment Europe Limited (collectively referred to as “SIEE”, “we”, “us” or “our” in this Privacy Policy) controls the personal data collected from you when you participate in our PlayStation user research.
SIEE respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect about you when you participate in our PlayStation user research, how we collect it, why we collect it, who we share it with, where it is processed, how we handle it and what your choices and legal rights are.
Before agreeing to take part in our PlayStation user research, it is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
For further information about this Privacy Policy or our processing of your personal data, please contact us by either of the following methods:
Post: Data Protection Office, Sony Interactive Entertainment Europe Limited, 10 Great Marlborough Street, London, United Kingdom, W1F 7LP
Online: siee.dpo@sony.com
Sony Interactive Entertainment Europe Limited is registered in England under company number 03277793.
SIEE is a data controller and gathers and uses certain personal data about you relating to your participation in our PlayStation user research. This means that we are responsible for deciding how we hold and use personal data about you.
Personal data means any information about a person that can directly or indirectly identify that person. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you including:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your session data to calculate the percentage of users accessing a specific device feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to compensate you for your participation in PlayStation user research). In this case, we may have to cancel your participation in our research but we will notify you if this is the case at the time.
We may process data concerning your health, such as whether you have a physical disability or medical condition, for the purposes of providing context for research findings related to the development of PlayStation games. Health data is a special category of personal data and we will not process or share such data with other SIE companies without first obtaining your explicit consent to do so. You may withdraw your consent at any time by contacting us at siee.dpo@sony.com.
We use different methods to collect data from and about you including through:
We will only use your personal data in accordance with applicable data protection laws and this Privacy Policy. Most commonly, we will use your personal data in the following circumstances:
We will only use your personal data 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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We keep your personal data during and after your participation in our user research for no longer than is necessary for the purposes for which the personal data is processed and in accordance with our records retention policy.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may share your personal data with other entities in the Sony group of companies (SIE Group) and, in the process of giving presentations to other third parties, such as publishers and developers working on PlayStation games, or at conferences. Other entities in the SIE Group, along with Us, may use your personal data to allow their development and research personnel to observe your research session at a later stage to help develop and improve PlayStation products and services and to illustrate internal reports and presentations. Personal data that we may share includes personal data collected before or after the session by or on behalf of SIEE (e.g. feedback, questionnaires and photos) and personal data collected during the session (e.g. feedback, recordings, device and test environment data).
Your information may also be available to third parties during negotiations for a transfer of all or part of our business and may be transferred by us as part of that business. We may retain, use and/or disclose any of your information as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.
We require all third parties to respect the security of your personal data and to take appropriate security measures to protect your personal data in line with our policies and in accordance with the law. We do not allow third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your information may be processed, stored and transferred outside your country of residence and beyond the United Kingdom (UK) and European Economic Area (EEA), where we are located for the purposes set out in this Privacy Policy, such as in the United States or Japan. Data protection laws in these countries may not offer the same level of protection as in your country, the UK or the EEA and you may have fewer legal rights in relation to your information. We ensure there are adequate safeguards in place when transferring your data outside your country, the UK and the EEA, including by relying on Privacy Shield, European Commission Standard Contractual Clauses or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law.
Where our processing of your personal data is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your personal data unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. Please contact our Data Protection Office (DPO) at siee.dpo@sony.com if you wish to object in this way.
Please contact our DPO if you would like to correct or request access to personal data that we hold relating to you or if you have any questions about this Privacy Policy. You also have the right to ask for your personal data that we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our DPO will provide you with further information about the right to be forgotten, if you ask for it.
We hope that our DPO can resolve any query or concern you raise about our use of your personal data, so please contact the DPO at siee.dpo@sony.com. If you are not satisfied with the resolution of your query or concern by our DPO, you do have the right to contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
