Privacy Policy for “Imaging Edge” Applications / Software / Web Services

This Privacy Policy sets out how Sony Imaging Products & Solutions Inc., (of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan) (“Sony”, “we”, “our” or “us”) collects, uses and/or stores the Collected Data (defined as below) regarding your “Imaging Edge” mobile applications, PC software and/or web services (collectively, “Imaging Edge”). It also describes your data protection rights, including a right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 below.

For the purposes of Regulation 2016/679 (the "GDPR") and other applicable privacy regulations where "data controller" is defined, Sony is the "data controller" of your personal data.

“Sony Group Companies” shall mean Sony Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony Corporation (the term “control” in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity).

1. What personal data do we collect when you use the Imaging Edge

Sony collects data as described below which may include personal information (collectively, the “Collected Data”) related to your use of Imaging Edge.

Information collected through the Imaging Edge

When you use each of the following, Sony will collect the following information respectively:

· Imaging Edge Mobile

1. Your Universally Unique Identifier (“UUID”) of Imaging Edge Mobile

2. Your UUID generated and given by Adobe

3. Information about Imaging Edge Mobile (e.g., software version, language and country/region settings)

4. Information about your smartphone/tablet (e.g., model name, manufacturer’s name, OS version, language and country/region settings)

5. Information about your camera device connected to the Imaging Edge (e.g., settings, errors/cautions, operation log including shooting dates/times, mount lens and mount media)

6. Information you provide in response to questionnaires regarding your level of skill as a photographer and the subjects you like to photograph

· Transfer & Tagging add-on (“Transfer”)

1. Your UUID of Transfer

2. Information about Transfer (e.g., software version, language and country/region settings)

3. Information about your smartphone/tablet (e.g., model name, manufacturer’s name, OS version, language and country/region settings)

4. Information about photographed images of your camera device connected to the Imaging Edge (e.g., file name, file size and caption data)

5. IPTC preset and user dictionary added or imported by you

6. Your voice when using the voice-input function

· Movie Edit add-on (“Movie”)

1. Your UUID of Movie

2. Information about Movie (e.g., software version, language and country/region settings)

3. Information about your smartphone/tablet (e.g., model name, manufacturer’s name, OS version, language and country/region settings)

· Imaging Edge (Remote/Viewer/Edit)

1. Your UUID of Imaging Edge (Remote/Viewer/Edit)

2. Your UUID of PlayMemories Home (if you use)

3. Information about Imaging Edge (Remote/Viewer/Edit) (e.g., software version, language and country/region settings)

4. Information about your PC (e.g., OS version)

5. Information you provide in response to questionnaires (including your level of skill as a photographer and the subjects you like to photograph)

· Imaging Edge Desktop

1. Your UUID of Imaging Edge Desktop

2. Your UUID of Imaging Edge (Remote/Viewer/Edit) (if you use)

3. Information about Imaging Edge Desktop (e.g., software version, language and country/region settings)

4. Information about your PC (e.g., OS version)

· Visual Story

1. Your UUID of Visual Story

2. Information about Visual Story (e.g., software version and installation date)

3. Information about your smartphone/tablet (e.g., model name, manufacturer’s name, OS version, language and country/region settings, and the number of smartphones you connected to Visual Story and used at each event)

4. Information about photographed images you uploaded to Visual Story (e.g., resized images transferred from your camera to your smartphone connected to Visual Story (including metadata information such as Exif and XMP), metadata information of the images (shooting date, orientation, focus position information, geolocation, etc.), information you added to the images (delivery, highlight, cover flag, etc.) and parameter information for image editing (brightness, white balance, etc.))

5. Information you provide in response to questionnaires (including your level of skill as a photographer and the subjects you photograph)

Please note that Sony also automatically receives device usage information about how you are using and interacting with the Imaging Edge, for example: information about which of the Imaging Edge functions you choose to use, picture transfer times and movie recording time.

If you install and use more than one Imaging Edge on the same device, Collected Data collected through either one will be linked to and analyzed in conjunction with Collected Data collected through the other by using your UUIDs only for the purposes set forth above. Also, if you use the Imaging Edge with PlayMemories Home on the same PC, Collected Data collected through the Imaging Edge will be linked to and analyzed in conjunction with Collected Data collected through PlayMemories Home by using your UUIDs solely for the purposes set forth below. Sony may also supplement Collected data with other data collected about you from third parties.

2. Purposes and legal basis for processing Collected Data

Contract

Sony processes Collected Data in order to perform its contract with you to provide the Imaging Edge.

Legitimate Interest

Sony also processes Collected Data in order to pursue its legitimate interests in:

1. Improving, developing and marketing products and services

Sony will collect and/or analyze Collected Data in order to improve Sony Group Companies’ products and services and to develop new ones, and to market and predict the demand for those products and services so that we can provide improved user experiences for current and/or future products and services.

2. Protecting Sony Group Companies and the Imaging Edge users

Sony may collect and/or analyze Collected Data in order to identify potential security threats and to protect Sony, Sony Group Companies and the Imaging Edge users.

3. Providing certain information and service related to your Sony digital camera product

If you use Sony digital camera product with the Imaging Edge, Sony will use Collected Data in order to provide you with information and recommendation regarding your Sony digital camera product and support service including repair of your digital camera product and response to your inquiry.

4. Providing certain information, service and advertising related to Sony products (FOR RESIDENTS IN THE US AND CANADA ONLY)

In addition to the foregoing, if you reside in the US or Canada, Sony will use Collected Data in order to provide you with information, recommendations and targeted and personalized advertisements regarding Sony products.

Where applicable, we have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

As required by law

We also process Collected Data where required to do so by applicable law, for example in response to requests by government or law enforcement authorities conducting an investigation.

3. Who else has access to Collected Data?

Collected Data that is communicated to and stored by Sony will be made available to other Sony Group Companies and to third party as follows:

Sony Group Companies and third party contractors

We will share Collected Data with Sony Group Companies, which locally sell and provide our products and services, solely for the purposes set forth above.

In addition, we will share Collected Data with Amazon Web Services who provides data back-up service to us, and which is located in the US. This contractor is engaged for the purposes of pursuing the activities outlined in this Privacy Policy on Sony’s behalf, acting as processors of Sony.

Firebase Crashlytics and Google Speech-to-text API

The Imaging Edge uses Firebase Crashlytics, a service provided by Google Inc. (“Google”) and the Transfer also uses Google Speech-to-text API, an API provided by Google. Firebase Crashlytics will track, prioritize and fix stability issues that erode quality of the Imaging Edge you use, and Google Speech-to-text API will be used for voice-input function of the Transfer. To better understand how Google uses the information it receives, visit: https://policies.google.com/privacy.

Adobe Analytics

The Imaging Edge Mobile uses Adobe Analytics, a service provided by Adobe Systems Incorporated ("Adobe"). Adobe Analytics will analyze how you use the Imaging Edge Mobile after turning your IP address into non-recognizable strings. To better understand how Adobe uses the information it receives, visit: https://www.adobe.com/privacy/policy.html.

Business transfer

In the event that we sell or transfer a portion or all of our business, Collected Data may be transferred by us to the purchasing or acquiring entity as part of the transaction. In the event we sell or transfer Collected Data to a purchasing or acquiring entity you will be duly informed.

Compliance and enforcement

We will retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.

4. Data Retention, Managing Collected Data

We will continue to retain Collected Data for as long as we continue to make the Imaging Edge available to customers, and for a further 6 months following discontinuation, at which point the information will either be anonymized or destroyed. Please note that we may be required to retain certain information by law.

5. International Transfer of Collected Data

Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan and the US. Collected Data will be processed by staff operating outside the EEA and/or your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries.

Sony takes appropriate measures to ensure that all transfers of Collected Data from the EEA to countries outside the EEA meet the requirements of applicable EU data protection legislation. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. If you have any questions or concerns about Sony's data transfer arrangements, please contact us using the details at Section 10 below.

6. Security

Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive to protect Collected Data, we cannot guarantee or warrant the security of any information transmitted to us through your Imaging Edge or that we store on our systems or that is stored on our third party contractors’ systems.

7. Our Policy Regarding Children

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 indicated in Section 10 below.

8. Privacy Rights (including the EEA and California/Other U.S. State Privacy Rights)

In some countries, including countries in the EEA, you have certain rights with respect to the personal information Sony holds about you. These may include rights to: request a copy of the personal information that we hold about you, and/or you may request that we correct, amend, delete the Information if it is inaccurate. In some countries, including countries in the EEA, you may also ask us to provide some types of the Information to you in a structured, machine readable format and ask us to share (port) such data with another controller. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete Information which we are required by law to keep or have compelling legitimate interests in keeping. If you would like to exercise any of these rights, please contact us as described in Section 10 below.

Notice to California Residents

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.

· CA Personal Information. Consistent with Section 1 above, we may collect certain categories of information about California residents ("CA Personal Information") for the purposes described in this Privacy Policy, specifically:

o Identifiers: such as UUID, IP address or similar identifiers;

o Usage Information: such as information about how you are using and interacting with Imaging Edge, page views, website traffic and similar information;

o Audio, Visual and Similar Electronic Information: such as voice commands or your photographs and images;

o Geolocation Data: such as country/region settings of Imaging Edge and/or your smartphone/tablet or metadata from images; and

o Other Consumer Characteristics: such as demographic information, preferences and interests.

· Sources of CA Personal Information. Consistent with Section 1 above, we may collect CA Personal Information from the following sources:

o Directly from you: such as when you use Imaging Edge; and

o Third-Party Partners: such as Sony Group Companies.

· Use of CA Personal Information. Consistent with Section 2 above, we may use CA Personal Information for the following business or commercial purposes:

Categories of CA Personal Information	Purposes of Use of CA Personal Information	Sources of CA Personal Information	Categories of Third Parties to whom we may disclose CA Personal Information
Identifiers	To provide Imaging Edge and other requested services; respond to your inquiries; send you information on products, services, promotions and other offerings and to personalize your experience with our products and services and online; provide you updates on your products, and use of our services; maintain and improve our products and services and those of Sony Group Companies; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	You; Sony Group Companies	Sony Group Companies; Data Analytics Providers; Legal Authorities (as required by law)
Usage Information	To personalize your experience with our products and services and online; maintain and improve our products, services and features; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	You; Sony Group Companies	Sony Group Companies; Data Analytics Providers; Legal Authorities (as required by law)
Audio, Visual and Similar Electronic Information	To provide services to you, including Imaging Edge and other requested services; maintain and improve our products and services and those of Sony Group Companies; internal business, legal and compliance purposes	You	Sony Group Companies; Service Providers; Data Analytics Providers; Legal Authorities (as required by law)
Geolocation Data	To send you information on products, services and promotions and other offerings and to personalize your experience on our Properties and online; maintain and improve our products and services; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	You	Sony Group Companies; Data Analytics Providers; Legal Authorities (as required by law)
Other Consumer Characteristics	To personalize your experience with our products and services; maintain and improve the products, services and features offered by us and the Sony Group Companies	You	Sony Group Companies; Data Analytics Providers; Advertising Networks

· CA Personal Information Sold or Disclosed For Business Purposes.

o 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: Identifiers; Usage Information; Audio, Visual and Similar Electronic Information; Geolocation Data; and Other Consumer Characteristics.

o Sale of CA Personal Information: In the preceding twelve months, we may have sold (as defined under CCPA) the following categories of CA Personal Information: Identifiers; Usage Information; Geolocation Data; and Other Consumer Characteristics.

California Consumer Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information: (i) Access. Request access to your CA Personal Information that we collect, use or disclose; (ii) Deletion. Request deletion of your CA Personal Information; and (iii) CA Personal Information Sold or Disclosed For Business Purposes. Request information about the CA Personal Information we have "sold" (as defined under CCPA) or 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 exercise a right listed in this section, you may submit a request here: Data Requests

“Do Not Sell My Personal Information.” If we sell your CA Personal Information to a third party, you have the right to opt-out of the sale of your CA Personal Information. If you wish to exercise this right, you may submit a request here: Do Not Sell My Info or call the following toll-free number 1-833-681-9900. If you are under the age of 16, we will not sell your CA Personal Information without affirmative authorization.

· Exercising Your Rights. If you are a California resident and wish to exercise any of these rights, please use the links above or you may: (a) contact us at privacy@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.

· Access Notice in Alternative Formats. Consumers who need assistance accessing the notice in an alternative format can do so by emailing us at: privacy@am.sony.com.

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.

Notice to Nevada Residents – Your Nevada Privacy Rights:

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. Sony 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 in case that Sony were to engage in such a sale in the future, you may submit your request in writing to: privacy@am.sony.com. 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 request. Sony will respond to valid requests within sixty (60) days.

9. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (whenever necessary under the applicable law) of any changes to this Privacy Policy through the Imaging Edge.

10. Contact Information

FOR RESIDENTS IN THE EU:

If you have any questions or concerns about this Privacy Policy or if you wish to exercise any legal right you have in respect of Collected Data, please contact Sony Europe BV, who is Sony’s representative in the EU, at:

privacyoffice.seu@sony.com

You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at http://sony-europe.com.

FOR RESIDENTS IN THE UK:

privacyoffice.seu@sony.com

You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.

FOR RESIDENTS IN KOREA:

We would designate a domestic representation according to Korea local regulation as following:

Name: Sony Korea Corporation (representative director: Okura Kikuo)

Address: 24F, One IFC, 10 Gukjegeumyung-Ro, Yeongdeungpo-Gu, Seoul, Korea Contact information: 02-1588-0911 / sokprivacy@sony.co.kr

FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:

If you have any concerns about how we process your data, you can find our contact details below or on the website of your local Sony Group Companies at:

The US: privacy@am.sony.com

Americas other than the US: http://www.sony-latin.com/locale-selector

Africa, Middle East and Asia & Oceania: http://www.sony-asia.com/countryselector.html

If you are not satisfied with how we have handled your questions or concerns, or have any complaints about how we process Collected Data, you have the right to complain to the local data protection supervisory authority in the place where you live or work or in the place where you believe a breach may have occurred.

Last Updated: 2020/2/10