Corporate Privacy Policy

Effective: April 1, 2021

This corporate privacy policy (“Corporate Privacy Policy”) applies to the information collected by Sony Global Education, Inc. (“Sony”), both offline and online, through www.sonyged.com and through any interactive features, applications, widgets, blogs, social networks and other online or wireless offerings that post a link to this Corporate Privacy Policy, whether accessed via computer, mobile device or other technology (“Corporate Websites”). Please note that when you enter any subsites of sonyged.com or use related Sony apps, such as “Global Math Challenge” or the KOOV app, such subsites and apps may have their own specific service privacy policies. Additionally, the websites of affiliated Sony companies, including some that are linked to/from the Corporate Websites, and internet domains that are linked to/from the Corporate Websites, may have different policies; therefore, please review the privacy policy notices on those websites if you visit them.

This Corporate 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 Corporate Privacy Policy carefully. In addition, please review our Terms & Conditions, which govern your use of the Corporate Websites.

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 and use the Corporate Websites, please note that in order to participate in some activities, such as sweepstakes, contests and other promotions (collectively, “Promotions”), chat rooms or bulletin boards, and some products and services we offer that require use of the Corporate Websites, we may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as first and last name, e-mail address, mailing address, telephone number or possibly, a picture) (“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 or use certain products that 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.

Individuals Under 16. The Corporate Websites are general audience sites. We do not target the Corporate Websites to children under the age of 16. If you are a parent or guardian who knows or has discovered that your child under the age of 16 has submitted his or her Personal Information or other information without your consent, permission or authorization, upon request, we will promptly: (a) provide direct notice to you indicating what, if any, Personal Information of your child has been collected and how it has been used and/or disclosed; (b) remove your child’s Personal Information or other information from our database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.

For Promotions. We may offer opportunities to enter into Promotions that we offer, on our own or jointly with a third party. Such Promotions may require registration and the disclosure of both Personal Information and non-Personal Information. In the event that a Promotion is offered jointly with a third party, as a result of your participation in such Promotion, your Personal Information and non-Personal Information may be shared with such third party, which sharing we will disclose to you at the time you provide your information. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other third parties connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore, always carefully read the rules of the Promotion before entering.

1.2 Information Sony Collects Automatically
In addition to any Personal Information or other information that you choose to provide to us via the Corporate Websites, whenever you visit or interact with the Corporate Websites, 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 Corporate Websites and any referring website. (A Device Identifier is a number that is persistently associated with your Device or that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) 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 Corporate Websites.

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 Corporate Websites (“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 Corporate Websites to collect Usage Information, including Device Identifiers, may include:

Cookies. “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 Corporate Websites or otherwise access our online offerings. Cookies may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your Corporate Website experience. If you choose to disable cookies on your Device, some features of our Corporate Websites and our online offerings 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 Corporate Websites, to monitor how users navigate the Corporate Websites, 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 Corporate Websites, 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 Corporate Websites, and is deactivated or deleted thereafter.

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 Websites 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 visitwww.allaboutdnt.com

One analytics provider with whom we may work is Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Corporate Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going togoogle.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available attools.google.com/dlpage/gaoptout.

1. 4 Social Media Applications
Functionality on the Corporate Websites may permit interactions between such Corporate Websites and a third-party website, such as enabling you to “like” a product or “share” content to third-party websites. If you choose to “like” or “share” content or to otherwise post information from or via the Corporate Websites to a third-party website, feature or application, that information may become public and the third-party web site may have access to information about you and your use of the Corporate Websites.

You may also choose to participate in a third-party application or feature (such as one of our Facebook applications or a similar application or feature on a third-party website) through which you allow us to collect and share (or the third party to share) information about you, including Personal Information. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or if information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party website or interactive service.

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 Corporate Websites;
• to determine which products and services we offer may be of interest to you;
• to process registration and other information you provide via our Corporate Website, including verifying that your email address is active and valid;
• to provide you with information about Promotions or other offerings that may be of interest to you;
• to provide you with support and answer questions or other requests; and
• for other purposes disclosed to you at the time you provide the Personal Information.

We may also use the information we collect to improve the Corporate Websites and our products and services, for internal business purposes, and to contact you with regard to your use of the Corporate Websites 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, and Usage Information with third parties in our discretion for a variety of purposes, 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.

To Affiliates and Other Sony Companies. 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. We may also share your Personal Information with Affiliates for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. For purposes of this Privacy Policy, “Affiliates” means any other entity directly or indirectly controlling or controlled by, or under common control with, Sony Group Corporation or one or more of the other Affiliates of Sony Group Corporation (or a combination thereof). For the purpose of this definition, an entity shall control another entity if the first entity: (i) owns, beneficially or of record, more than fifty percent (50%) of the voting securities of the other entity; or (ii) has the ability to elect a majority of the directors of the other entity.

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, 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 a third party (which may include Affiliates), your Personal Information may be shared with that 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 Corporate Websites, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.

When You Consent To Have Your Personal Information Shared or Otherwise Request That We Share Your Information. We may offer you the opportunity to consent to the sharing of your information with third parties. Such reasons include, without limitation, so that you are able to receive information and/or marketing offers from third parties. Additionally, you may request, sometimes through your use of an interactive feature or third- party application, that we share Personal Information about you with a third party, and we will typically do so in those circumstances. If you agree or request to have your Personal Information shared (either by opting in, choosing not to opt-out or using a specific feature of the Corporate Websites), your Personal Information will be disclosed to the applicable third party(s) and the Personal Information you disclose will be subject to the privacy policy and business practices of such third party(s); therefore, please consult the respective privacy policies of each third party. If you consent or request to receive communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.

The provisions above apply to our sharing of Personal Information with Affiliates and third-party service providers. They do not cover use of Personal Information that those Affiliates and third-party service providers collect directly from you. Such use of Personal Information is covered by the relevant Affiliate’s and/or third party’s privacy policy and not this Privacy Policy.

Business Transactions. Sony or any of its assets, including the Corporate Websites, may be sold, or other transactions may occur in which your Personal Information is one of the key business assets in the transaction (such as bankruptcy). 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 (including, without limitation, during the course of any due diligence process).

Legal Protections and Law Enforcement. We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), 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 & Conditions 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 Corporate Websites 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. Such disclosures may be carried out without notice to you.

4.Links To and Sony Content On Other Websites

The Corporate Websites 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, Sony content or widgets may be included on web pages and websites that are not associated with us and over which we have no control. These other websites may send their own cookies to your Device, and they may independently collect data or solicit Personal Information. A link from any Corporate Website to any other website does not mean that Sony approves of, endorses, or recommends that website. Sony provides such links for your convenience and is not responsible for the content of any website linked to or from any Corporate Website. Moreover, 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 on any other website.

5.Notice to California Residents

California Privacy Notice(Effective 2020):

If you reside in California, we are required to provide additional information to you about how we collect, use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

5.1 CA Personal Information.

Consistent with this Privacy Policy, we may collect the following categories of information about California residents (“CA Personal Information“) for the purposes described in this Privacy Policy, specifically:
o Personal Identifiers: personally-identifiable information such as your name, address, telephone number, etc.;
o Device Identifier such as your IP address and/or another unique identifier for the computer, mobile device, technology or other device;
o Usage Information such as your browser type, operating system, the page served, the time at which you accessed a page and/or the time you spent on a page, and your preceding pages views, and
o Other Consumer Characteristics: such as other information about yourself such as demographic information or certain information about your preferences and interests.

5.2 CA Personal Information Sold or Disclosed For Business Purposes.

•Sharing your CA Personal Information for Business Purposes: In the preceding twelve months, we may have shared the following categories of CA Personal Information for business purposes: Personal Identifiers, Device Identifiers and Usage Information, and Other Consumer Characteristics. This information may be shared for the purpose of providing services to you, delivering communications, for legal compliance, or to manage or protect legitimate interests, in compliance with law.
• Sale of CA Personal Information: We do not “sell” (as defined under the California Consumer Privacy Act) any categories of CA Personal Information.

5.3 California Consumer Rights.

Subject to certain exceptions, as a California resident, you may have the following rights with respect to your CA Personal Information: (i) Access. Request access to your CA Personal Information that we have collected, used, or disclosed within the preceding 12 months; (ii) Deletion. Request deletion of your CA Personal Information; and (iii) CA Personal Information r Disclosed For Business Purposes. Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months. To the extent permitted by applicable law, we may be required to retain some of your CA Personal Information and certain CA Personal Information is strictly necessary in order for us to fulfill the purposes described in this Privacy Policy. If you wish to submit an access or deletion request, please click here:Data Requests.

5.4 Exercising Your Rights.

If you are a California resident and wish to exercise any of these rights, please: (a) contact us by sending an email toprivacy@am.sony.com with the specific nature of your request, referencing “Your California Privacy Rights”; or (b) call the following toll-free number 1-833-681-9900. When submitting your request, you must include your first and last name, email address, and zip code or mailing address. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that you are limited by law in the number of requests you may submit per year.

We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, or in connection with any promotions or other offerings, based solely upon you exercising your rights to your CA Personal Information.

Authorized Agents: To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code. We may require additional proof of authority or may need to contact you directly to validate the request.

Additional Notice to California Residents:
If you are a California resident, under the California “Shine the Light” law, you have the right to receive: a) information identifying any third party company(ies) to whom Sony may have disclosed, within the past year, personal information pertaining to you and your family for that company’s direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to Privacy@am.sony.com and include your name, email address, and a reference to “Your California Privacy Rights”. We are not responsible for requests that are not labeled or sent properly, or do not have complete information.

6.Security and Retention

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 data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid ‘phishing’ scams, where someone may send you an e-mail that looks like it is from Sony asking for your Personal Information. Sony will never request your Personal Information through e-mail.

To help protect you and others, we monitor use of the Corporate Websites, and we use the information we collect, including Personal Information, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Corporate Websites; ensure compliance with the applicable terms of service and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of Sony, its affiliates, partners and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through the Corporate Websites. If you do not consent to these conditions, you must discontinue your use of the Corporate Websites.

You understand that any message or information you send to a Corporate Website may be read or intercepted by others. Sony does not ensure or warrant the security of any information you transmit to us, and you use the Corporate Websites and provide us with your information at your own risk.

7.Consent to Processing

The Corporate Websites are operated in Japan. If you are located in the United States, the European Union, Canada or elsewhere outside of Japan, please be aware that information we collect will be transferred to and processed in Japan. By using the Corporate Websites, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in Japan, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

8. 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, without prior notice to you, and any changes will become effective immediately upon posting. Your continued use of the Corporate Websites after posting of any changes to this Privacy Policy will constitute acceptance of, and agreement to be bound by, those changes. Thus, please review this Corporate Privacy Policy periodically.

9.Questions

If you have any questions or comments about 5. Notice to California Residents of this Privacy Policy, please contact us as provided in that Section. Otherwise, if you have any questions or comments about our practices regarding Personal Information or about this Privacy Policy, please contactwww.sonyged.com/contact/.