SPN Privacy Policy

Privacy Policy

Sony Pictures Networks (“SPNI”, “We”, “Our”, “Us”) respects your privacy. This Privacy Policy is applicable to personally identifiable information (hereinafter referred to as “ Personal Information ” and detailed below) collected, processed, stored and used in connection of an individual’s Users (“User” / “You”/ “Your”) access or use of the SPNI Connect application (“ Application”/“App”). This Privacy Policy explains what Personal Information We collect through the Application, how We use the said Personal Information, and what choices you have with respect to the said Personal Information. Please take a few moments to read this Privacy Policy.

This Privacy Policy should be read in conjunction and together with the Terms of Use. By using the Application, you agree to Our terms of processing your Personal Information in accordance with this Policy.

Access to the services

The access to the Application is available only to the SPNI employees, SPNI contractors and associated partners of Multiple System Operators (MSOs) for DTH and Cable, Internet Protocol television (IPTV), Headend in the Sky (HITS) and Local Cable Operators (LCOs) associated with SPNI (“ Users / you / your ”).

Further, the access to the Application is available only through registration. In case you are a roaming user or if you are a traveller visiting various countries around the world and want to avail the services offered on the Application, please bear in mind that you will be required to notify Us so that we can inform you if the services are available in your region and if you can avail Our services. The details and consent obtained from you at the time of registration will be subjected to the applicable laws and regulations of the country You register in.

Moreover, it is advised that you should not access or use Application by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN). We will not be responsible or liable for any consequences or claims (legal or otherwise and including but not limited to any user requests) with respect to processing of your Personal Information if you use any mechanism or technology to access or use the Application which conceals your actual geo-location.

What information we collect

‘Personal Information’ 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 information, the resulting information also is treated as personal information. SPNI captures the Personal Information from you, since We cannot identify you by a pseudonym or through anonymous data.

Types of Personal Information we collect

Registration Information – Registration information collected when you register on the Application including but not limited to your first name and surname, state, country, pin code, date of birth, email address, contact number, alternate contact number, anniversary date, profile picture, company name, company logo, company website, number of employees, office address, MSO Company ID, LCO Company ID, Tenant ID, External ID, User ID and password;

Location Information – Location information inferred by a mobile number, country code, address, pin code provided or your IP address;

Device Information – Device information consists of unique identifier assigned to every device as well as details regarding mobile network and manufacturing details. This may include Device UUID, Application ID, Device Hardware ID, Registration ID;

In App permissions – We ask you to provide permissions to Storage and Camera in order to provide you with certain application features;

Activity Information – Aggregate information about your activity on the Application, such as the content you view or post, participation in contests, and your preferences if any;

Complaints and Feedback – Information about the complaints or feedback that you register with SPNI such as email id, contact number along with any comments, complaints or feedback that you share with Us.

How we use the Personal Information we collect

SPNI is responsible for and may use your Personal Information for the purposes described in this Policy. Consistent with applicable law and choices and controls that may be available to you, we may use Personal Information collected from you, or from devices associated with you, to:

Process Your registration on the Application;
Determine Your geographic location and provide details of content available in the said territory;
Enable You to access the Application and enjoy more seamless access to the Application;
Enable You to use and receive the services offered on the Application including e-mail communications informing you about the services and content provided by Us through the Application;
Contact you about your Account and in connection with any services or content support, feedback through the Application;
Provide you with marketing materials;
Enable your participation in contests, polls, marketing events;
Improve and enhance the Application usage experience according to your preferences and relating to User business interests;
Increasing security measures to keep your Personal Information safe by preventing, detecting and investigating potentially prohibited or illegal activities;
Support security measures, such as requiring re-login into the Application after a certain amount of time has elapsed;
Profiling and analysing the User behaviour to generate general and customer analytical insights/needs and requirements of the Users in a particular territory in relation to Our content and provide enhanced services;
Notify you about changes in terms of service or in this Privacy Policy;
Other purposes specifically disclosed to you prior to the collection of your Personal Information or otherwise with your consent

The Personal Information obtained from you will be processed by Us for the purpose of the above-mentioned purposes and none other. In the event, We wish to process your Personal Information for purposes other than those mentioned herein, We shall seek specific consent from you prior to such processing.

How we share information

SPNI currently does not share your Personal Information with any associated third parties, vendors or personnel for any purposes. However, we might share your Personal Information under the following circumstances:

To comply with a legal obligation; when We believe, in good faith, that such disclosure is required under the law for Us to be compliant with such law or at the request of any governmental authorities conducting an investigation. Pursuant to valid requests by law enforcement agencies, We may also share device identifiers or any form of Personal Information 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.
To verify or enforce the Application’s Privacy Policy, Terms of Use or other applicable policies;
To respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, users or the public.
With other entities affiliated with us for internal reasons, primarily for business and operational purposes. Subject to your explicit consent (as provided under this Privacy Policy) to receiving marketing materials from Our affiliated companies, we may share your e-mail address and information on your preferences and interests with such affiliated companies in order for them to provide you with certain marketing and promotional communication. We or any of its assets, including the Application, may be acquired/merged/de-merged/spun-off and/ or any other transactions may occur in which your Personal Information is one of the business assets of the transaction, your Personal Information may be transferred.

What choices you have

SPNI provides you the ability to exercise certain controls and choices regarding Our collection, use and sharing of your Personal Information. In accordance with applicable law, your controls and choices may include:

Correcting, updating, and deleting your personal information;
Requesting access to the Personal Information we hold about you.

Please note that if You request for the deletion of Personal Information; We may retain some of the Personal Information as may be required for our legitimate business interests, such as fraud detection and prevention and enhancing safety. We may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, We may keep some of your Personal Information for tax, legal reporting and auditing obligations.

You can drop us an e-mail at SPND_Marketing@setindia.com to action the above requests.

Children’s Privacy

We do not intend to collect or knowingly collect information from any person who has not attained age of 18. In the event We collect Personal Information of any minor, We will obtain a parental consent from the minor’s parent or legal guardian prior to processing such Personal Information.

COMMITMENT TO PRIVACY AND CHOICES

SPNI respects your privacy and is committed to protecting the Personal Information that you provide, in connection with your use of its Application. SPNI takes reasonable and appropriate precautions to protect your Personal Information from unauthorized disclosure and to prevent possible security breaches. SPNI has implemented a code of best practices for data protection which is compliant with the IS / ISO / IEC 27001 standard and hence in compliance with the standards set out under the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

SPNI incorporates commercially reasonable safeguards to help protect and secure your personal information. However, because electronic data can be intercepted, corrupted, lost or destroyed, please note that SPNI cannot ensure or warrant the security of any data, and your use of the Application is at your own risk. We are continuously implementing and updating administrative, technical and physical security measures to help protect your information against unauthorized access, loss, destruction or alteration If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact Us using the contact information provided below.

NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

By virtue of use of the Application You hereby agree, accept and consent to the terms as specified under this Privacy Policy and upon notice of any changes to the Privacy Policy, User’s continued use of the Application will be considered acceptance of those changes by you and will constitute your agreement to be bound thereby. If you object to any terms of this Privacy Policy, your sole recourse will be to stop using the Application.