Privacy Policy

Sony Pictures Networks India Private Limited (“Company”, “we”, “us”, “our”) is committed to protecting the privacy and security of your personal data. Your privacy is important to us.

This SPN ACE Privacy Notice (“Notice”) applies to all users who are onboarded as part of our business relationship and governs all interactions, communications, and data processing activities on the SPN Ace application (“application”), explaining the manner in which the Company collects, receives, stores, discloses, shares, uses and otherwise processes certain individually identifiable information of its User (“User Data”) in connection with them with the Company.

1. TYPES OF PERSONAL DATA WE COLLECT

The Company collects, holds, uses and processes the following categories of User Data:

  1. General personal information: Name, email address, phone number, state, city, pin code, date of birth, Date of anniversary, MSO/LCO affiliations or organization details, photographs
  2. Technical Data: Device type, OS, session logs, app login activity, sections visited, password

2. PURPOSE OF COLLECTION

The Company collects, holds, uses, and otherwise processes the User Data for the purposes described below, or for purposes which are reasonably compatible to the ones described below:
  • Processing for consent as a lawful basis where processing is necessary such as:
    • Sign up to use the application.
    • Participate in contests on the application.
  • Processing for legitimate uses where processing is necessary such as:
    • To ensure compliance with our legal obligations and to also comply with our obligations towards public authorities
    • To enforce any legal right or claim
    • For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention or prevention of fraud

3. DISCLOSURE AND SHARING OF USER DATA

As a part of its normal business operations, the Company may disclose the User Data in the manner detailed below. User Data is shared with only those third parties that provide an adequate level of data protection by implementing appropriate technical and organizational security measures as prescribed by applicable law. We do not sell User Data to anyone.
A. General Disclosure:

User Data may be disclosed to:

  1. a limited number of restricted individuals within the distribution and IT departments, will receive access to User Data, when necessary, in connection with their job responsibilities.
  2. Company’s other affiliated or group companies.
  3. in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), to the purchaser or subscriber for shares in the Company or any company within the Company’s group.
B. Regulatory compliances and legal disclosures:

The Company may share the User Data when required for the following purposes:

  • To comply with legal obligations and compliance requirements such as disclosures made to authorities
  • To respond to requests, orders, notices etc. from government agencies, including law enforcement agencies and other public authorities;
  • To prevent, detect, investigate offences, complaints, cyber incidents, for the prosecution or punishment of offences;
  • To raise or defend against legal claims (whether in relation to respective User or otherwise);
  • To protect the Company’s users, systems, and products and/or services.
  • to verify or enforce the Company’s applicable policies;
  • to protect the rights, property, safety, or security of third parties, users or the public or in response to a similar emergency.

4. TRANSFER OF USER DATA OUTSIDE INDIA

The Company operates globally and may transfer the User Data in territories outside India for the purposes described in this Notice and in accordance with applicable data protection laws in such territories. Such transfer of User Data may be to its affiliated or group companies or to third parties, primarily for business and operational purposes.

5. RETENTION OF USER DATA

The Company will retain the User Data for as long as the Company reasonably considers it necessary for achieving the purposes detailed in the Notice and as is permissible under applicable law. The Company may archive and/or retain the User Data for as long as there are statutory retention obligations or potential legal claims are not, yet time barred.

6. SECURITY PRACTICES AND PROCEDURES

The Company has adopted reasonable security practices in compliance with applicable laws to secure the User Data. The Company shall also ensure that the third parties to whom User Data is transferred or disclosed, will have at least the same level of security practices as that followed by the Company.

7. YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL DATA

You have the following rights:
  • Right to access: User can request access to their User Data held by the Company. User can write to privacyqueries@setindia.com with their requests
  • Right to correction: User has the right to correct any inaccurate or incomplete User Data. User is responsible for informing the Company if there are any changes or inaccuracies to their User Data. User should transmit any requests for access or updates to, or corrections or deletions of their own User Data
  • Right to erasure: User have the right to request the erasure of their personal data in certain circumstances. If you believe that we should discontinue the use of your personal data, you have the option to request the deletion of your personal data, unless retention is necessary for compliance with any law for the time being in force.
  • Right of grievance redressal: Any grievance related to the processing or handling of the of User Data shall be intimated to the Ombudsman at Ritesh.Khosla@setindia.com
  • Right to nominate: In the event of death or incapacity to exercise these rights, you can nominate any other individual to exercise such rights.
  • Right to withdraw your consent: User has a right to withdraw their consent for the activities they had consented for, although the right will have limited applicability as only in cases where consent based processing does apply. The withdrawal of consent previously granted for the processing of personal data does not affect the lawfulness of the processing until the withdrawal. However, opting out will result in cessation of the respective services
  • Right to Information: User have the right to be informed about the collection and use of their User Data. In the event the Company intends to use the User Data for any purposes not covered under this Notice, the Company shall inform you about such additional processing, and where required, might seek your explicit consents.

For exercising any of the above rights, you can write to privacyqueries@setindia.com. You may be asked to furnish proof of your identity before you can exercise these rights. The Company may not be able to process any requests made in the event you fail to establish your identity, or if we are unable to authenticate your identity.

8. CHANGES TO THIS PRIVACY NOTICE

The Company reserves the right to change this Notice, at our sole discretion at any time. Any material changes to this Notice will be posted on ………… We encourage you to review this Notice and Company’s Privacy Policy, regularly for such changes. The updated Notice will take effect as soon as it has been updated.
I have read and understood this Notice. I understand its content and expressly and voluntarily consent to the application of its terms, including those regarding the collection, use, storage, disclosure, transfer and other processing of my User Data by Sony Pictures Networks India Private Limited.