Privacy Policy / Your California Privacy Rights

Effective: September 4, 2018

This privacy policy (“Privacy Policy”) applies to the information collected by Takeoff Point LLC, a subsidiary of Sony Corporation, (“Sony”, “our” or “we”), both offline and online, including through https://www.takeoff-point.com/ and related websites or through any applications or other interactive features, widgets, blogs, social networks and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology (collectively “Services”). Please note that when you enter any subsites accessible through https://www.takeoff-point.com, such subsites may have their own specific privacy policies. Additionally, the websites of affiliated Sony companies, including some that are linked to/from the Services, and internet domains that are linked to/from the Services, may have different policies; therefore, please review the privacy policy notices on those websites if you visit them. This Privacy Policy explains the information that Sony may collect when you interact with us and our practices with respect to that information. Please read this Privacy Policy carefully.

1. Collection of Information

1.1 Information You Provide To Sony

In General

While Sony does not generally require that you provide us with personally identifiable information in order to visit our websites, please note that in order to participate in some activities, such as signing up for an account and using or purchasing our Services, , we may ask you to provide information that identifies you as a specific individual (such as first and last name, address, e-mail address, mailing address and telephone number) (“Personal Information”). We may also ask you to provide other information about yourself, such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. If you choose not to provide such Personal Information or other information to us, you may not be able to participate in certain activities we offer. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information. We may also de-identify Personal Information, turning it into non-Personal Information. This is sometimes accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.

Individuals Younger Than Age 13. (For US residents)

The Services are directed to a general audience. We do not knowingly collect personal information from anyone younger than the age of 13, and Sony will delete any personal information later determined to be inadvertently collected from a user younger than age 13.

1.2 Information Sony Collects Automatically

In addition to any Personal Information or other information that you choose to provide to us via the Services, whenever you visit or interact with the Services, Sony automatically collects certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access the Services and any referring website. (A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) We may directly collect specific location information from your Device if you have opted-in to such collection through one of our mobile applications. You may be able to turn off the collection of location information through your Device settings. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Services.

In addition, Sony, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the Services (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if Sony associates it with you as a specific and identifiable person, we will treat it as Personal Information.

1.3 Cookies and Other Tracking Technologies.

The technologies used on the Services to collect Usage Information, including Device Identifiers, may include the technologies described below. You may be able to disable cookies and similar technologies by adjusting your browser settings to disconnect the link between cookie information and non-personal viewing information generated by those technologies.

The methods used to collect Usage Information may include the following:

Cookies & Local Storage. “Cookies” (which may be html files, Flash files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit the Services or otherwise access our online content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Services may make use of this local storage. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies Flash cookies, and other local storage devices may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your experience. You may refuse or remove some or all of these cookie and local storage technologies; however, if you choose to do so, some features of our Services may not function properly.

Web Beacons. “Web beacons” (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

2. Uses of the Personal Information Sony Collects

Sony will use the information it collects, including your Personal Information:

to tailor your experience on the Services;

to determine which products and services we offer may be of interest to you;

to allow you to participate in the Services and features offered through the Services;

to process your registration with the Services, including verifying that your email address is active and valid;

to send you special offers from us, our advertisers, or third-party business partners;

to allow you to participate in the public areas and other features of our websites;

to tailor content, recommendations, and offers we display to you, both on the Services and elsewhere online;

to provide you with customer service, support and answer questions or other requests; and

for other purposes disclosed to you at the time you provide your information or otherwise with your consent, and as further described in this Privacy Policy.

We may also use the information we collect to improve the Services and our products and services, for internal business purposes, to comply with regulatory and legal obligations and to contact you with regard to your use of the Services and, in our discretion, changes to any of our policies.

3. When and With Whom Sony May Share Information Collected

Non-Personal Information.

We may share non-Personal Information, such as aggregate user statistics, demographic information, de-identified information and Usage Information with third parties in our discretion, including tailoring promotions, advertising and communications we present to you.

Personal Information.

We may also share your Personal Information, as specifically disclosed at the time you provide your Personal Information and in the following circumstances:

To Affiliates, Other Sony Companies and Third-Parties.

Sony may share your Personal Information with companies affiliated with Sony (“Affiliates”), so that those Affiliates can (i) assist us with fulfilling your requests or improving our products, content, services or advertising; and/or (ii) contact you about products, content, services or other offerings that may be of interest to you. For purposes of this Privacy Policy, “Affiliates” means Sony Corporation, any company with respect to which Sony Corporation owns, directly or indirectly, 50% or more of its outstanding shares, and any company with the name "SONY" as a part of its trade name.

To Third-Party Service Providers Providing Services On Sony’s Behalf.

We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your Personal Information with third party service providers that assist us with providing content, payment processing, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Sony. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your Personal Information may be shared with that Affiliate or third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information in order to host or operate the Services, and for data analysis purposes.

Business Transfers.

We may share your Personal Information with other entities affiliated with us for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. In addition, Sony or any of its assets, including the Services, may be sold, or other transactions or transitions may occur whether voluntary or involuntary (such as through bankruptcy) in which your information, including your Personal Information, is one of the key business assets in the transaction. In such a case, your Personal Information may be one of the business assets we transfer. Hence, Sony reserves the right to disclose and transfer user information, including Personal Information, in connection with any activity and/or transaction described above. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

We may transfer and disclose information, including your Personal Information, to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms of Service or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the Services or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion.

4. Analytics and Similar Third Party Services and Your Choices

We may use a variety of companies to perform advertising and analytics services including:

Google Analytics

We utilize Google Analytics in order to collect and analyze access log by using cookie. Please note that it does not store any personally identifiable information in its cookies. All the logs will be maintained under Google privacy policy. Please find here for more detail information about Google privacy policy.

We also use Google Analytics Advertising Features in order to obtain demographic and interest reports. We utilize first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together to analyze your other information and your interest. If you choose to opt out Google Analytics Advertising Features, please disable Cookies by setting your browser or use Google Analytics Opt-out Browser Add-on.

Hotjar

We may utilize Hotjar or a similar program in order to aggregate data on our website visitors’ behavior using cookies. Please note that Hotjar does not collect any personal information in its cookies. Examples of the type of information collected include, but is not limited to, pages visited, interaction on pages, device and browser type, and the geographic location.

To learn how Hotjar collects data, the type of data it collects, or how to opt out of data collection from Hotjar, please visit Hotjar’s privacy policy. Feel free to opt-out of tracking by Hotjar here.

The Services may contain links to other websites that are operated and controlled by third parties that we do not control. This includes links of advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. In addition, the Services or other Sony content may be included on web pages and other online services that are not associated with us and over which we have no control and which may send their own cookies to your Device and independently collect data or solicit Personal Information. A link from any Service to any other online content does not mean that Sony approves of, endorses, or recommends it. Sony is not responsible for the privacy practices of any third party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content it does not own and control.

6. Notice to California Residents

Your California Privacy Rights: If you are a California resident, you have the right to receive once per calendar year: (a) information identifying any third party(ies) to whom Sony may have disclosed, within the preceding calendar year, your personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information free of charge, please email us at: privacy@am.sony.com or write to us at: Sony Electronics Inc., Personal Information Management Office, 1 Sony Drive, MD 1E4, Park Ridge, NJ 07656. Sony will respond to these requests within thirty (30) days. Requests that come to Sony by other means may result in a delayed response. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

"Do Not Track" Signals- Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Services do not currently interpret, respond to or alter their practices when they receive Do Not Track signals. Please note that third parties may collect personal information about your online activities over time and across different websites when you visit our website or other online websites and services. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.

7. Security

Sony uses commercially reasonable safeguards to help protect and secure your Personal Information, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of Personal Information we share with them. However, no electronic or wireless data transmission or electronic storage of information can be guaranteed to be 100% secure. Sony does not ensure or warrant the security of any information we collect, and you use the Services and provide us with your information at your own risk.

By providing any Personal Information to Sony, all persons, including without limitation persons in the member states of the European Union, fully understand and unambiguously consent to the collection and processing of such information in the United States of America, and/or in territories or countries outside of the United States of America, and understand and acknowledge their consent, notwithstanding that some governmental authorities may consider the level of protection of such data in the United States not equivalent to that required within the European Union or any other jurisdiction. By visiting the websites and using the Services, or providing us with any information, you fully understand and unambiguously consent to the transfer, processing and/or storage of your information in another country, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

9. Policy Governs Use: Changes to Privacy Policy

The terms of this Privacy Policy will govern the use of any information collected while it is in place. Sony reserves the right to change this Privacy Policy at any time and will notify you of material changes by posting the revised Privacy Policy on our Services. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will become effective immediately upon posting unless otherwise specified. We will not use your Personal Information in a manner materially different from the Privacy Policy in effect at the time we collected your Personal Information without your consent, but your continued use of the Services after posting of any changes to this Privacy Policy will constitute acceptance of, and agreement to be bound by, those changes. Note that you may need to consent to the new or revised policy in order to continue to access or use the Service.

10. Questions

If you have any questions or comments about our practices regarding Personal Information or about this Privacy Policy please email us at: privacy@am.sony.com