Updated and Effective: July 2023
What does this policy cover?
Table of Contents
- What Information Do We Collect?
- How Do We Use This Information, and What Is the Legal Basis For This Use?
- Who Will We Share This Information With, and Where?
- How Do We Treat Children's Personal Information?
- Transfer of the Collected Data Internationally and Consent to Processing
- Contact Us
- State Notices
- Notice to Virginia, Colorado, and Connecticut Residents
- Notice to Nevada Residents
- Notice to California Residents
- Further Information for EEA/UK Individuals
- Further Information for Residents in Québec, Canada
What information do we collect?
Information You Provide.
We collect information from you directly when you visit the SCS Websites. We may also collect information automatically, such as your IP address. Some of this information may be considered "personal information" or "personal data," and some of which may be considered "sensitive" under various applicable laws. Depending on how you use the SCS 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, billing address, and telephone number). SCS may also ask you to provide other information about yourself, which includes categories such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. Additionally, if you transact business with us, including to purchase a subscription, our third-party service provider may collect financial information such as your payment method (valid credit card number, type, expiration date, or other financial information).
Therefore, the information that we collect and process from you may include:
- your name;
- your address, e-mail address and phone number;
- your marketing preferences, including any consents you have given us;
- a password you create for use on the website
Information We Collect Automatically
In addition to any personal information or other information that you choose to provide to us via the SCS Websites, SCS 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 SCS Websites 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.) 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 SCS Websites. You may be able to turn off the collection of location information through the settings on your Device. 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.
Usage Information. In addition, SCS, 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 SCS Websites ("Usage Information"). Usage Information may include, without limitation, 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 page views. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.
Therefore, the information that we may automatically collect from you and process may include:
- Your IP address or another unique identifier, such as a Device Identifier
- Information related to your Device such as the platform, operating system, browser type, or physical location
- Your Usage Information such as the content served, the time at which the content was accessed and/or the time spent using the content, and the preceding content views
“Do Not Track” and Global Privacy Control 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. When you choose to turn on the “Do Not Track” settings in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com
Global Privacy Signals. Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more about and to set up GPC, please visit https://globalprivacycontrol.org/#about.
How do we use this information, and what is the legal basis for this use?
We process this personal information for the following purposes:
- As required for business purposes or to establish and fulfill a contract with you, for example fulfilling an online software purchase or product registration.This may include verifying your identity, communicating with you and providing services relevant to our business, including providing customer services and arranging the delivery or other provision of products, prizes or services.
- As required by SCS to enable our business and pursue our legitimate interests, in particular:
- we will use your information to provide services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of the SCS Websites, and may use your information to help us monitor, improve and protect our content, services and SCS Websites, both online and offline;
- we may use information you provide to tailor your experience on our SCS Websites or personalize our services for you;
- we may use your information to provide you with information about contests, sweepstakes or other promotions (collectively, "Promotions") or other offerings that may be of interest to you;
- we will use your information to provide you with support and answer questions or other requests;
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- we may use information you provide to investigate any complaints received from you or from others, about the SCS Websites or our products or services;
- we may use your information to invite you to take part in market research or surveys;
- we may also use the information we collect to improve the SCS Websites and our content and services, for internal business purposes, and to contact you with regard to your use of the SCS Websites and, in our discretion, changes to any of our policies.
- For compliance with applicable laws and protection of SCS's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, and investigative purposes (including disclosure of such information in connection with legal process or litigation).
- For purposes disclosed at the time you provide your personal information, or otherwise with your consent.
We may also use and share non-personal information in our discretion, and we may use non-personal information, including information that has been de-identified or pseudonymized to improve the SCS Websites. In addition, in accordance with applicable laws, we may send you direct marketing in relation to our services, or other services provided by our Affiliates and carefully selected partners. You will be able to opt-out of those materials by following the instructions in the communication. To control your direct marketing settings, please visit https://www.sonycreativesoftware.com/mailprefs.
Who will we share this information with, and where?
SCS may share the personal information we collect from you to other Sony affiliated companies ("Affiliates"). Affiliates include: (i) Sony Corporation, (ii) any company of which 50% or more of its outstanding shares are owned by Sony Corporation, directly or indirectly, and (iii) any company with the name "SONY" as a part of its trade name) who may provide services to us, assist us with fulfilling your requests or improving our content, services or advertising, or want to contact you about products, services or other offerings that may be of interest to you (SCS and such Affiliates being collectively referred to as "Sony"). We may share this personal information for a variety of purposes, including to (i) provide you with or contact you about content, products, services or other offerings that may be of interest to you; (ii) administer offers or Promotions; (iii) develop business and products; (iv) support various business processes and provide services; (v) provide customer service; (vi) to secure, monitor, and ensure compliance and legal obligations are met; and (vii) conduct customer analysis, research and development.
To Third-Party Service Providers Providing Services on SCS's Behalf
We may 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 content, services, or advertising, or otherwise performing services for us. 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 SCS Websites, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment 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 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. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar vendors, and they will use this information to help us, and their other clients prevent fraudulent and illegal transactions.
Third Party Business Partners
We may offer you the opportunity to consent to the sharing of your information with unaffiliated third parties, for example so 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 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.
We may share personal information with Affiliates for internal reasons, primarily for business and operational purposes, including any corporate reorganization, restructuring or other corporate change. In addition, SCS or any of its assets, including the SCS Websites may be sold, or other transactions may occur in which 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. By providing your information, you understand and agree that we may transfer such information, in connection with any activity and/or transaction described above, without your further consent, except where otherwise required by law.
Legal Protections and Law Enforcement
We may transfer and disclose information, including your personal information, (including Usage Information and Device Identifier (including IP address)), to third-parties: (i) to comply with legal obligations; (ii) to prevent fraud; (iii) when we believe in good faith that the law requires disclosure; (iv) at the request of governmental authorities conducting an investigation; (v) to verify or enforce our Terms of Service ( https://www.sonycreativesoftware.com/corporate/terms) or other applicable policies; (vi) to respond to an emergency; or (vii) to otherwise protect the rights, property, safety or security of third-parties, visitors to the SCS 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.
Social Media Applications
You may 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 property) 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.
SCS uses commercially reasonable safeguards to help protect and secure 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' schemes, where someone may send you an e-mail that looks like it is from SCS asking for your personal information. You understand that any message or information you send to SCS Website may be read or intercepted by others. SCS does not ensure or warrant the security of any information you transmit to us, and you use the SCS Websites and provide us with your information at your own risk.
How do we treat children's personal information?
We do not knowingly collect or permit the collection, storage or use of any personal information from anyone under 16. Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries. If you are a parent or guardian and are concerned that your child has provided us with personal information without your consent, you should contact us as set out below.
For Residents of the United States
If you are a parent or guardian who knows or has discovered that your child under the age of 13 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.
Transfer of the Collected Data Internationally and Consent to Processing
Your personal information may be processed, stored and transferred to countries/regions outside of Canada, including in particular the United States and Japan. By providing us with any information, you fully understand and consent to this transfer, processing and storage of your information in the United States, Japan and other jurisdictions, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. Further, courts, law enforcement, and other authorities in countries/regions outside of your country of residence may be entitled to access your personal information upon its transfer.
Or you may write to us at:
c/o Sony Electronics Inc.
115 West Century Rd., Suite 250
Paramus, NJ 07652
Notice to Virginia, Colorado, and Connecticut Residents
Right to Know: the right to confirm whether we are processing Personal Data about you.
Right to Correct: the right to correct inaccurate Personal Data we hold about you.
Right to Delete: the right to delete the Personal Data provided by you or obtained about you.
Right to Data Portability: the right to access your Personal Data and obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.
If you are an eligible consumer and would like to submit a request to exercise any of these rights, please complete the form here: Data Requests
Right to Opt-out of Targeted Advertising: SCS does not engage in online advertising and analytics practices that may be considered "targeted advertising", therefore, we do not offer this right.
Right to Opt-Out of Profiling or Sale of Personal Data: While state laws may permit you to opt-out of the sale of your Personal Data and out of profiling in furtherance of decisions that produce legal or similarly significant effects, we do not engage in either of these activities at this time.
Right to Appeal: Pursuant to applicable law, if, for any reason, you would like to appeal a decision made by us relating to your request or your exercise of a right, you have the right to submit an appeal and can do so by completing this form: Data Requests. Please include your full name, the basis for your appeal, and any additional information to consider.
Notice to Nevada Residents
If you are a Nevada resident, you have the right to opt-out of the sale of certain personally identifiable information we have collected about you to third parties. SCS does not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if SCS were to engage in such a sale in the future, you may submit your request in writing to Privacy@am.sony.com., or as described in the Contact Us section. Your request must reference your Nevada rights and include your name, mailing address, zip code, and email address. Your request is subject to verification of your identity by us and validation of your request. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your SCS will respond to valid requests within sixty (60) days.
Notice to California Residents
This California Privacy Notice is effective as of July 1, 2023.
California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights regarding your CA Personal Information:
- Right to Know. Request information regarding what Personal Information that we have collected, used, disclosed, or sold, including the right to request that we provide you with the categories and/or specific pieces of Personal Information we have collected from you;
- Right to Delete. Request deletion of your Personal Information, provided that we may retain certain Personal Information as required or permitted by law;
- Right to Correct. Request correction of inaccurate Personal Information we maintain about you;
- “Do Not Sell or Share My Personal Information.” Request to opt-out of the "sale" of your Personal Information or the "sharing" of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). As we do not knowingly collect Personal Information of residents younger than the age of 16, we also do not knowingly sell or share for cross-context behavioral advertising their Personal Information
"Limit the Use and Disclosure of Sensitive Personal Information." Under the CPRA, a business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or does not fall under certain statutory exceptions. SEL's use and disclosure of Sensitive Personal Information is not used for such purposes and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
More information on each of these rights is below.
Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can't respond to your request if we can't verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
Exercising Your Rights
Right to Know, Delete, Correct. If you are a California resident and wish to exercise your Right to Know, Right to Delete, and/or Right to Correct, please:submit your request here: Data Requests; or you may call us toll-free number 1-833-681-9900.
For requests to know, in order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. For requests to delete, we may follow up with you and require you to confirm that you want your information deleted.
Do Not Sell or Share for Cross Context Behavioral Advertising. California Consumers have the right to opt-out of the "sale" or "sharing" of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). We do not "sell" Personal Information or "share" it for cross-context behavioral advertising, and therefore we do not offer this right.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. 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, based solely upon you exercising your rights to your Personal Information.
Authorized Agents. If you are an authorized representative submitting a request on a consumer's behalf, please complete the applicable request per the instructions in this notice. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer's identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer's behalf, we may deny the request.
Data Retention. We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Properties or continuing to interact with us.
Click here to access our data reporting metrics for the previous calendar year.
Notice of Financial Incentive. Under California regulations, if we offer certain loyalty, discount, or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a "financial incentive". In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.
Information We Collect & Purposes for Collection. Consistent with this Privacy Notice, we may collect the following categories of information about California residents ("Personal Information") for the following purposes. In addition to the below described in Table 1 we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CPRA.
|Categories of Personal Information Collected||Business or Commercial Purposes for Collection of Personal Information||Categories of Sources from Which Personal Information Was Collected||Categories of Service Providers/ Third Parties to Whom We May Disclose Personal Information for a Business Purpose||Categories of Third Parties to Whom Personal Information is Sold or Shared for Cross Context Behavioral/Targeted Advertising|
Such as: name, address, and email address, and online or device identifiers such as Device IDs, IP address, Advertising ID.
| || |
Consumers; Sony Group companies; Third-Party Business Partners; Consumer Data Providers
Sony Group companies; IT Service Providers/Email/Messaging Vendors; Customer Support Providers; Payment Processors; Business Partners; Legal Authorities (as required by law); Business Transfer Recipients.
|Any categories of personal information described in subdivision (e) of Section 1798.140* |
Such as: name, contact information, financial information and online or device identifiers such as Device IDs, IP address, Advertising ID.
*Some of this information may also be included in other categories of information
| ||Consumers; Sony Group companies; Third-Party Applications||Sony Group companies; Customer Support Providers; Business Partners; Payment Processors; Legal Authorities (as required by law); Business Transfer Recipients.||None|
|Commercial Information |
Such as: products or applications purchased,credit card or payment information, or transaction history.
| ||Consumers; Sony Group companies; Business Partners||Sony Group companies; Service Providers; Business Partners; Legal Authorities (as required by law); Business Transfer Recipients.||None|
|Audio, Visual and Similar Electronic Information |
Such as: pictures or videos or the audio recordings.
Provide features and services, including customer service;quality assurance, manage participation and use of the services, programs, and similar online offerings
|Consumers; Sony Group companies||Sony Group companies;IT Service Providers; Customer Support Providers; Data Analytics Providers; Legal Authorities (as required by law); Business Transfer Recipients.||None|
|Internet or Other Electronic Network Activity |
Such as: computer and connection information, browser type, operating system, page views, traffic to and from the websites, and other standard weblog information collected via cookies, web beacons, and related tracking technologies.
| ||Consumers; Sony Group companies; Social Media Applications||Sony Group companies; Service Providers; Legal Authorities (as required by law); Business Transfer Recipients.||None|
|Sensitive Information |
Such as: account log-in/password information, ethnicity, health information, precise geolocation or biometric information; government identifiers.
|Provide you with requested services, features and functions; maintain and improve our products and services; authentication of your account; monitor and help maintain security of our systems and prevent fraud; internal business, legal s and compliance purposes||Consumers||Sony Group companies; IT Service Providers; Customer Support Providers; Data Analytics Providers; Legal Authorities (as required by law); Business Transfer Recipients.||Geolocation Data is not “shared” or “sold” to third parties.|
|Inferences Drawn from Other Information and Consumer Characteristics |
Such as: characteristics that may include demographics (e.g., gender, age, region, profession or job title), interests or hobbies, and inferences drawn may relate to, purchase or browsing history.
|To develop and deliver marketing communications; to personalize your experience on our services and online; develop, maintain and improve the products, services and features offered by us and the Sony Group companies||Consumers; Sony Group companies; Third-Party Business Partners; Social Media Applications; Consumer Data Providers||Sony Group companies; Service Providers; Legal Authorities (as required by law); Business Transfer Recipients.||None|
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 companies to whom SCS 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. Requests must include a reference to "California Shine the Light - SCS". We are not responsible for requests that are not labeled or sent properly, or do not have complete information.
Further Information for EEA/UK Individuals
What rights do I have in relation to my personal data?
You may be entitled to ask SCS for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations. You may also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at https://www.sonycreativesoftware.com/contact/privacy
If you have unresolved concerns, you also have the right to complain to your local data protection authorities.
Which SCS entity is my data controller?
The data controller for your personal data is Sony Creative Software Inc.
How long will you hold my data?
Where will you send my data?
By providing any personal data to SCS, all persons, including without limitation persons in the member states of the EEA, UK, and Switzerland, 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. Where information is transferred outside the EEA, UK, and/or Switzerland to a third country that is not subject to an adequacy decision, data is adequately protected through the use of standard contractual clauses, or another authorized transfer mechanism.
Further Information for Residents in Québec, CanadaThis notice sets forth disclosures and rights for consumers residing in Québec, Canada regarding their personal information, as required by the Québec’s Data Privacy Law 25.
Contact information for SCS’s Privacy Officer:
Sony Electronics Inc.
Attn: Privacy Officer
115 West Century Rd., Suite 250
Paramus, NJ 07652
Telephone: 1-833-681-9900 (toll free)
Automated Decision Making: SCS does not use personal information to render any decisions based exclusively on an automated processing of such information.
Residents of Québec’s Consumer Rights:
Subject to certain exceptions, you may have the following rights regarding your personal information:
- Right to Access. Request to confirm the existence of the personal information, communicate it to you, and allow you to obtain a copy of it;
- Right to Rectify. Request rectification of inaccurate personal information we maintain about you.
Exercising your rights: If you are a Quebec resident and wish to exercise your Right to Access, and/or Right to Rectify, please: submit your request here: Data Requests; or you may call us toll-free number 1-833-681-9900.