PRIVACY AND COOKIES POLICY
This Privacy and Cookies Policy applies to the websites, apps, and online features (“Content”) that link to this Privacy and Cookies Policy (“Policy”). In this Policy, we use "SPE," or "we," "us," and "our" to collectively refer to the relevant Sony Pictures Entertainment Inc. ("Sony Pictures") entity that, together with Sony Pictures, is responsible for a particular site or app. You can also learn more about cookies and similar technology which we use in this Policy by reviewing the terms below.
KEY POINTS
We use personal information to allow you to use the features in the Content, to process your registration, and to provide you with requested Content related to our movies and other offerings. Click here to learn more.
If you give us permission, we will send you news and promotional material about SPE. You can change your mind at any time and ask us not to process your personal information for direct marketing purposes. Click here to learn more about your rights and how you can exercise them.
We provide interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these sites will send us personal information about you. Click here to learn more.
We use cookies and other tracking technologies to personalize Content and advertising and to make our Content function better. To learn about our use of tracking technologies click here.
Most of our Content is not designed for children. We may ask for your age before you can sign up to receive newsletters or to use our Content. Click here to learn more.
When you make a purchase from one of our sites or apps, we will use your personal information to fulfil your order. We will share your personal information with our third-party partners to process your payment and perform some of the other fulfilment on our behalf. Click here to learn more.
We disclose your personal information publicly when you post user-generated content via our sites or apps. We disclose personal information when you agree that we can share data with our business partners or other Sony group companies. We also share data with third parties we engage to process data on our behalf or when such sharing is required or permitted by law, or in certain other situations. Click here to learn more.
We transfer your personal information to the United States or other jurisdictions in which we or our service providers are located. Click here to learn more.
INFORMATION WE COLLECT
Information SPE and its service providers may collect may include personal information such as your first and last name, e-mail address, phone number, address, payment card information, interests and preferences, and interactions with the Content as well as information collected automatically when you access or use the Content such as IP address, device identifier, digital identifiers such as cookie IDs, browser type, operating system, and data regarding network connected hardware (e.g., computer or mobile device). We use this usage information to help us understand user activity and to monitor and improve the Content. We may also collect data through cookies and similar tracking technologies as described below.
If you communicate with us by telephone, we may record customer service calls with you for quality assurance and training purposes.
If you use our streaming service, we also collect information about the shows you watch, follow or add to your queue, as well as your search queries and we use and share this information as permitted by applicable law.
We also receive personal information from third parties as described below.
HOW WE USE YOUR INFORMATION
We may use personal information collected via our Content:
A. To process your registration on a site or app, or entry into a competition, prize draw or contest
B. To send you information about changes to our terms or policies and other transactional messages
C. To process your payment and fulfil your purchased order or subscription service
D. To create and administer your online account or subscriptions
E. To provide you with access to Content and features in the sites and apps
F. To respond to your questions or inquiries, or send you information you have requested
G. To ensure the security of our sites and apps, by trying to prevent unauthorized or malicious activities
H. To enforce compliance with our Terms of Use and other policies and to help other organizations (such as copyright owners) to enforce their rights
I. To tailor Content, advertisements and offers for you
J. If you use our streaming services, to provide you with personalized content based on your viewing behaviour and interests, and to analyze and better understand our audience, improve our service and recommendation algorithms
K. Where you ask us to send marketing information to you via a medium where we need your consent (for example, email or SMS text marketing), in which case we will tailor our communications so that they are more relevant to you based on your interactions with SPE entities
L.To place cookies and to use similar technologies (as described further below), including to determine your location and manage digital content rights (e.g. territory restrictions)
M. On other occasions where we ask you for consent, for a purpose which we explain at that time
N. Where we need parental consent to provide online services to children as required by law
We retain personal information for so long as we think is reasonably necessary for the purposes described above.
INFORMATION WE RECEIVE FROM THIRD PARTIES
Sometimes, we receive information about you from third parties. For example, if you login to a site or app using Facebook Connect you will be asked if you wish to share information from your Facebook account with us. If you participate in a game or other feature where your score is posted on a social media content, or if you use a "like" or a "share" button for a feature on our sites or apps, then the third party will share information with us.
If you participate in activities on non-SPE sites or apps - such as participating in a Facebook application - you may allow us to have access to personal information held by Facebook, or other site or app owners.
We will also receive personal information about you if individuals give us access to their profiles, or similar features, on non-SPE sites or apps, and you are one of their "connections".
Some of our Content has 'send to a friend' features. The ‘send to a friend’ feature is when users can ask us to send features to their friends. If a friend asks us to send you a feature via email or other communications, then we will process your contact details (i.e. email address) in order to send you communications on behalf of your friend. The contact details are only used to send you the feature and we do not retain the contact detail. If you want to use this feature, you should only provide your friend's contact details to us when you know they would like to hear from us. Your friend will know that you provided their contact details to us. Your contact information and message may be included in the communication.
If we provide online services to a child where we need parental consent for this, we may ask for a parent's email address, in order to obtain the consent.
COOKIES AND SIMILAR TRACKING TECHNOLOGY
Cookies, web beacons (also known as "tracking pixels"), location-identifying technologies, and other tracking technologies may be used by SPE and third parties including other Sony group companies to collect information about interactions with the Content or e-mails, including information about your browsing and purchasing behavior.
These cookies and similar tracking technologies allow us to recognize you when you visit a site, or app, or open an email – they do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.
We use tracking technologies for three purposes:
A. To provide you with the service you have requested: for example, keeping you logged in during your visit and ensuring security of the Content.
B. To show advertisements that are more relevant to your interests: for example, with your consent, we and third parties such as ad networks and other advertising companies use tracking technologies (including cookies and pixel tags) on our Content and other websites and apps to collect information about your activity across your different devices, including Content you have visited or that has interested you and advertising you have interacted with and then use this to make predictions about your preferences and help us and third parties serve more relevant ads to you, including when you are on another site or app. To manage your preferences or opt-out of this type of interest-based advertising, please see “How to Manage Tracking Technologies” below. Tracking technologies also help limit the number of times that you see an ad across your devices, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed so we can pay for this. We also allow other organizations to use tracking technologies for these advertising purposes too.
C. We may also work with third-party platforms and websites (such as social networking platforms) to serve targeted advertisements on such third-party services and platforms to you or others, and we may convert your email address, telephone number, or other information into a unique value and provide it to these third-party platforms for matching purposes. You may opt-out of the use of your information for such purposes by unsubscribing from our marketing email communications as described under “Controlling Marketing Communications” below.
D. To analyze and improve your browsing experience: to analyze which Content is most popular and gets viewed the most and which gets viewed the least, and to provide us with general information about users of the Content (such as age, gender and interest areas). We also check for bugs and glitches in the Content and remember the choices you have made, such as your language or region, to enhance and personalize your experience. We use analytics services provided by Adobe and Google to help us do this. If you don’t want us to use information about your visits in this way, click here for Adobe and here for Google, to opt-out of their services.
How to manage tracking technologies
If you are using our Content via a browser you can change your cookie preferences and withdraw your consent at any time using the Cookie Consent Tool.
In addition:
the Help menu on the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to delete old cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. However, if you decide not to accept cookies from the Content, you may not be able to take advantage of all of the Content features.
you can also opt-out of analytics as described above.
For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
We use Flash cookies to provide some Content such as video clips or animation. Flash cookies are managed through the Flash Player Settings Manager, which is a different interface than the one provided by your web browser. This Settings Manager lets you manage global privacy settings, storage settings, security settings, and automatic notification settings. Beginning with Flash Player 10.3, the Flash Player Settings Manager can be accessed locally on your computer: in the Control Panel on Windows and in System Preferences on Mac. Users of other operating systems and earlier versions of the Flash Player should manage their global privacy settings using the Flash Player Settings Manager are provided online from Adobe by clicking here.
Location-identifying Technologies
We may use GPS (global positioning systems) software, geo-filtering and other location-aware technologies to locate (sometimes precisely, in compliance with applicable law) you for purposes such as verifying your location and delivering or restricting content (e.g. territory restrictions) and advertising based on your location. You can turn off geo-location tracking through the location settings on your device.
PlayStation Devices, Apple iOS and Android Devices
By accessing certain applications from these devices, you consent to cookies being stored to your device for the following purposes: keeping you logged in, managing parental control PINs, analytics and advertising. Other than advertising cookies, these cookies are essential to the operation of the application. It is not currently possible to opt out or remove these essential cookies from the devices without deleting the application. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC’s AppChoices tool, please download the version of AppChoices for your device at https://youradchoices.ca/appchoices/.
HOW WE SHARE YOUR PERSONAL INFORMATION
If we ask you for consent to share your personal information with third parties for their own marketing purposes, and if you give consent, we will share personal information with these third parties. We do not share your personal information with third parties for their own marketing unless you agree to this.
If you register for a promotion, such as a competition, prize draw or contest, which is administered by a third party, your personal information will be shared with the organizer for them to administer the promotion. This may also mean that your personal information will be included on a winners list.
If you submit user-generated content to a site or app this will be disclosed publicly.
We share data with third parties (including other SPE entities) who perform functions on our behalf for the purposes listed in Section 1 above, such as hosting or operating our site and apps, sending e-mails, and carrying out data analysis and advertising services. Where you make a purchase on one of our sites or apps, we will share your personal information with third parties to process your card payment and deliver your order.
We share your personal information with other SPE entities which are involved when we process data for the purposes listed at section 1 above. Where you give permission, we will also share your personal information with other Sony group companies for them to use for advertising or direct marketing purposes.
SPE or any of its assets, including the Content, may be sold, or other transactions may occur in which your personal information may be considered one of the business assets of the transaction. In this case, your personal information may be transferred, either as part of the transaction or during any due diligence process.
We and our service providers may share information with government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings to comply with a legal obligation, when we believe in good faith that the law requires it, where this is necessary for us or for third parties to protect our or their rights, property, safety, or security or as otherwise required or permitted by applicable law (which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate).
TRANSFER
Our sites and apps are hosted and operated by us or our service providers in the United States and other countries. Your personal data will be transferred to and processed in the United States and to other countries which may be outside the country in which you live, where the privacy laws may not provide an equivalent level of protection to those in your home country. For international transfers of your data to Sony Pictures Entertainment entities, Sony group companies or to our service providers, we have put into place appropriate safeguards to protect your data, such as Standard Contract Clauses which have been approved by the European Commission or the regulatory agency in the country you live in. If you would like a copy of the standard contractual clauses or have other queries, please contact us.
ACCESSING AND UPDATING YOUR PERSONAL INFORMATION,
Subject to limited exceptions under applicable law, you have the right to access your personal information in our records and, if necessary, have it amended. You may also ask us to provide some types of personal information to you, or another organization nominated by you, in a structured and machine-readable format. You may request updating of inaccuracies in your personal information in our custody or control by contacting us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
CONTROLLING MARKETING COMMUNICATIONS
You can also ask us not to send marketing communications and not to use your personal information when we carry out profiling for direct marketing purposes. You can opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. If you sign up to receive SMS or MMS messages, you can unsubscribe from those messages received by replying "STOP." Transactional account messages will be unaffected if you opt-out from marketing communications.
PRIVACY QUESTIONS
For more details or any privacy questions, please contact our privacy team by email at SPE_CAN_Privacy@spe.sony.com or write to us at the relevant address here.
CHANGES TO THIS POLICY
We reserve the right to change the terms of this Privacy and Cookies Policy at any time, by prominently posting notice of the amendment on the site or app. To the extent permitted by law, these changes will apply from the time they are posted.
Effective Date: This Privacy and Cookies Policy is effective as of December 21, 2020.
Effective Date: December 21, 2020. Prior versions of this policy are available here.
To download and/or print this Privacy Policy ("Privacy Policy"), click here.
PRIVACY POLICY OVERVIEW
Welcome! An overview of this Sony Pictures Entertainment Inc. Privacy Policy is below. To see the full text click on the links provided. This Privacy Policy applies to your use of any online services (e.g., website or mobile app) that posts a link to this Privacy Policy, regardless of how you access or use it. Click here to view our Terms of Use. A Children’s Privacy Policy may be posted on applicable portions of the Service .
Your Choices and Your CA Privacy Rights
You have certain choices regarding information collection and communications options explained here, including:
Questions and How to Contact SPE
For more information about SPE’s privacy practices regarding the Service, read the full Privacy Policy. You can also contact SPE here if you have questions or concerns.
Use of Information
The information SPE collects is used for a variety of purposes as detailed in this Privacy Policy. For example, your information helps SPE provide and improve the Service, communicate with you, serve advertising and offers to you, and operate SPE’s business. More
Collection of Information
Sharing of Information
SPE may share the information SPE receives from or about you via the Service (or give others access to it), including your Personal Information, for a variety of purposes, as detailed in this Privacy Policy. More. These include, without limitation:
SPE obtains your consent (e.g., opt-in, opt-out), however, before knowingly sharing Personal Information SPE collects from you on the service with third parties (other than Sony group companies, except as otherwise required by applicable law) for their own direct marketing purposes. More
SPE may share your non-Personal Information, aggregate and/or de-identified information about you except as prohibited by applicable law. More
FULL SPE PRIVACY POLICY
Thank you for visiting an online service (e.g., website or mobile app) that posts a link to this Privacy Policy ("Service") owned or operated by Sony Pictures Entertainment Inc. or one of its family of companies (collectively, "SPE"). This Privacy Policy will provide you with information as to how SPE collects, uses, and shares information about you, including the choices SPE offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to SPE’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
By visiting or otherwise using the Service, you agree to the Service’s Terms of Use and consent to SPE’s collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service (including any Children’s Privacy Policy). If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.
COLLECTION OF INFORMATION
A. Information You Provide.
i. i. SPE, and/or its Service Providers (defined below), may collect information you provide directly to SPE and/or its Service Providers via the Service. For example, SPE collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact with SPE through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third- Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
ii. Information SPE, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies, or is reasonably capable of identifying you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number, or your device, including certain digital identifiers, such as cookie Ids ("Personal Information"); and (2) non-Personal information, such as (to the extent permitted by applicable law) your interests ("non-Personal Information"). In addition, Personal Information, including, without limitation, SPE-Collected PI (defined below), once "de-identified" (i.e., the removal of personal identifiers from data or other means to make it no longer reasonably identifiable and no attempt made to reidentify the information to an individual) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. To the extent any non- Personal Information is combined by or on behalf of SPE with Personal Information SPE itself collects directly from you on the Service ("SPE-Collected PI"), SPE will treat the combined data as SPE-Collected PI under this Privacy Policy.
B. Information Collected Automatically.
SPE, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service ("Usage Information"). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include:
Cookies
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your device for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML 5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit:
www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices.
Web Beacons ("Tracking Pixels")
Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, to count content views, and to measure the effectiveness of our advertising and email marketing.
Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from SPE’s web server, or from a third party with which SPE works, and is active only while you are connected to the Service, and deleted or deactivated thereafter.
Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content and advertising based on your location.
Fingerprinting
Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.
Device Recognition Technologies
Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household).
In-App Tracking Methods
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices.
Some information about your use of the Service and certain Third-Party Services may be collected using Tracking Technologies across time and services, and used by SPE, Sony group companies, and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain ThirdParty Services. See Section 11 regarding certain choices regarding these activities.
SPE is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
C. Information SPE Collects From Partners and Other Sources.
SPE may also obtain information about you from other sources, including SPE’s affiliates ("Sony group companies"), Service Providers and Third-Party Services, and combine that with SPE-Collected PI. Such third-party-sourced, or non-Service-sourced, information (including Personal Information) will only be treated as SPE-Collected PI to the extent it is combined with SPE-Collected PI. SPE is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.
USE OF INFORMATION
SPE may use information about you, including SPE-Collected PI and other Personal Information, for any purposes consistent with SPE’s statements under this Privacy Policy and not prohibited by applicable law, including, without limitation, the following:
SHARING OF INFORMATION
SPE may share non-Personal Information, and Personal Information that is not deemed SPE-Collected PI hereunder (provided that SPE is aware of no restrictions on SPE’s use, if any), with third parties, including without limitation other Sony group companies for any purpose. SPE’s sharing of SPE-Collected PI is, however, subject to the following:
SPE may also share any information about you (including, without limitation, SPE-Collected PI) for any purposes consistent with this Privacy Policy, or otherwise not prohibited by applicable law, including, without limitation:
SWEEPSTAKES, CONTESTS, AND PROMOTIONS
SPE may offer sweepstakes, contests, and other promotions (each, a "Promotion"), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to SPE, co-sponsors, Service Providers, Sony group companies, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.
INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS
The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including SPE. Notwithstanding anything to the contrary, Personal Information included in UGC is not subject to SPE’s usage or sharing limitations, or other obligations, regarding SPE-Collected PI or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by SPE and third parties to the extent consistent with this Privacy Policy or not prohibited by applicable law. SPE encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.
Additionally, the Service may offer you the option to send a communication to a friend. If so, SPE relies on you to only send to people that have given you permission to do so. The friend’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by SPE for any other marketing purpose unless SPE obtains consent from that person. Your contact information and message may be included in the communication.
THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties ("Third-Party Service(s)". These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you. Their privacy policies apply in such cases, and not this Privacy Policy.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third- Party Services, such as third-party social networks ("Social Features"). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” SPE’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service(e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third- Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with SPE or Sony group companies in a tweet or status update), your post may be used on or in connection with the Service or otherwise by SPE and Sony group companies. Also, both SPE and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
SPE may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on Third-Party Services. Some of these ads may be tailored to your interest based on, for example, your browsing of the Service and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” ("Interest-based Advertising"), which may include sending you an ad on a Third-Party Service after you have left the Service (i.e., “retargeting”).
SPE may use Service Providers for analytics services such as, without limitation, Google Analytics. These analytics services may use cookies and other Tracking Technologies to help SPE analyze Service users and how they use the Service. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other internet usage.
Except to the extent SPE combines information from Service Providers, Third-Party Services, or other third parties with SPE-Collected PI, in which case SPE will treat the combined information as SPE-Collected PI under this Privacy Policy (see Section 1(c)), data obtained by SPE from a third party, even in association with the Service, is not subject to SPE’s limitations regarding SPE-Collected PI under this Privacy Policy. However such data remains subject to any restrictions imposed on SPE by the third party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with SPE, the types of information shared, and your choices on what is visible to others on Third- Party Services.
SPE is not responsible for and makes no representations regarding the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.
DATA SECURITY AND MONITORING
SPE takes reasonable measures to protect SPE-Collected PI (excluding UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and SPE cannot guarantee the security of your information collected through the Service.
To help protect you and others, SPE and its Service Providers may (but make no commitment to) collect and use information including usage of the Service, SPE-Collected PI and other Personal Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of SPE and Sony group companies, their partners, and customers. Such monitoring may result in the collection, logging, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.
INTERNATIONAL TRANSFER
SPE is based in the U.S. and the information SPE and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.
CHILDREN’S PRIVACY
The Service is intended for a general audience and not directed to children less than 13 years of age. Some portions of the Service, however, may be intended as appropriate for a mixed audience of users under and over 13 years of age (e.g., a separate “Kids” section), or exclusively for users under 13 years of age. For further information on how SPE treats Children’s Personal Information (defined below) in connection with any children’s or mixed-use portions of the Service (if any), please see the Children’s Privacy Policy posted thereon, which will be deemed incorporated herein for purposes of that part of the Service.
SPE does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act ("COPPA") ("Children’s Personal Information") in a manner that is not permitted by COPPA, and for any children’s or mixed-use portions of the Service (if any) SPE will comply with COPPA. If you are a parent or guardian and believe SPE has collected Children’s Personal Information in a manner not permitted by COPPA, please contact SPE here and SPE will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request removal by contacting SPE here, detailing where the content or information is posted and attesting that you posted it. SPE will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that SPE does not control. SPE does not "sell" (as that term is defined by the California Consumer Privacy Act (CCPA)) Personal Information gathered from sites that link to the Children's Privacy Policy. For further information regarding the sale of Personal Information under the CCPA, please see Section 12.B. below.
ACCESSING AND CHANGING INFORMATION
If you have registered an account with SPE, SPE provides you with tools and account settings to access, correct, delete, or modify the information you provided to us and associated with your account. SPE will make good faith efforts to make such requested changes in SPE’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all your information or public postings from SPE’s databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law..
CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
A. Tracking Technologies Generally.
Regular cookies and tracking pixels, among other Tracking Technologies, may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. You can also manage the use of some Tracking Technologies such as without limitation cookies and tracking pixels by using SPE’s Cookie Consent Tool. Please be aware that every website utilizes its own cookies, so cookie preferences should be set for each SPE website. If you choose to opt out of any Tracking Technologies such as without limitation cookies and pixels, a preference cookie will be placed on your device in order to honor that opt-out. If you later clear your browser and delete cookies from your device, by doing so you will also remove the preference cookie. Therefore, in order to remain opted out of Tracking technologies, you will have to go back to the Cookie Consent Tool and renew your choices. Please remember that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can be disabled by uninstalling the app and in some instances by using the Cookie Consent Tool in the app you are using. To uninstall an app, follow the instructions from your operating system or device manufacturer.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus as to what “Do Not Track” means in this context. Like many online services, SPE currently does not alter SPE’s practices when SPE receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com, but SPE is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. SPE is not responsible for the completeness or accuracy of third party choice notices or choice mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
B. Analytics and Advertising Tracking Technologies.
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Microsoft by going to http://privacy.microsoft.com/en-us/privacystatement.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance’s("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising online, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Opting out does not mean that you will no longer receive ads, but that the ads you see will no longer be relevant to your preferences. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use of a different device or web browsers or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. SPE supports the ad industry’s 2009 Self-Regulatory Principles for Online Behavioral Advertising ( https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf). SPE is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Mobile Apps.
With respect to SPE’s mobile apps ("apps"), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. See also the prior section regarding the DAA’s mobile Interest-based Advertising choices.
D. Communications.
You can opt out of receiving certain promotional communications (emails or text messaging) from SPE at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from SPE to text the word, “STOP”. Please note that your opt- out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt- out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, SPE may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or SPE’s ongoing business relations.
E. Audience Measurement.
The Service may feature Nielsen proprietary measurement software, which will enable you to contribute to market research, such as Nielsen TV Ratings. To learn more about the information that Nielsen software may collect and how to opt out, please see the Nielsen Digital Measurement Privacy Policy at http://www.nielsen.com/digitalprivacy
YOUR CALIFORNIA PRIVACY RIGHTS
A. California's "Shine the Light" Law
SPE only knowingly shares personal information (as defined by California’s “Shine the Light” law), with non- affiliated third parties (i.e., parties other than Sony group companies except as otherwise required by applicable law) for their own direct marketing purposes if you specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out, to such sharing at the time you provide personal information or choose to participate in a feature on the Service. If you do not opt in or if you opt-out at that time, SPE will not knowingly share the personal information that was collected in connection therewith with such identified non-affiliated third party(ies) (or Sony group companies where required by applicable law) for its/their own direct marketing purposes, but may continue to seek your consent to sharing with the same or other non-affiliated third parties (or Sony group companies where required by applicable law) for their own direct marketing purposes from time-to-time. Each consent notice and opportunity will be treated separately so it is possible that you may consent to some sharing but not to others.
In addition, California residents may request information about SPE’s compliance with the Shine the Light law and the Sony group companies with which SPE may have shared personal information for their direct marketing purposes by contacting SPE here or by sending a letter to Sony Pictures Entertainment Inc. at 10202 W. Washington, Jimmy Stewart Building, Culver City, CA 90232 (Attention: Privacy Program, Information Security). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that SPE is only required to respond to one such request per customer each year, and SPE is not required to respond to requests made by means other than through the provided e-mail address or mail address.
B. The California Consumer Privacy Act (also known as the “CCPA”)
If you are a California resident, California law also provides you with specific rights regarding your Personal Information which are set forth in more detail below.
The Right to Delete Personal Information and the Right to Know About Personal Information Collected, Disclosed, or Sold
As a California resident you have the right to request SPE to delete Personal Information which SPE has collected from you and the right to request from SPE what Personal Information about you it has collected, used, disclosed, and “sold” about you (as the term “sale” is defined under the CCPA: “the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration”)and the right to request that we stop any such “sales.” SPE does not share consumers’ Personal Information in exchange for money. SPE shares Personal Information with third parties and service providers in compliance with the law in order to deliver more meaningful ads and other communications to consumers, and for other similar reasons provided in this policy. SPE does not sell Personal information gathered from sites that link to the Children's Privacy Policy referenced in Section 9 above.
SPE will take reasonable steps to verify your identity using information you submit with your request before the request will be processed. We may request additional information from you. To submit a request, you can click here or contact us at 1-800-782-6588. If you have visited the SPE studios in Culver City, California in person, please click here. Your request is subject to exceptions allowed by law. Please note that SPE is only required to respond to two such requests per California resident each year and only requests from California residents whose identity SPE can reasonably verify.
Right to Opt Out of the Sale of Personal Information
A California resident has the right to opt- out of the sale of their Personal Information by a business. To submit such a request, please click here or call us at 1-800-782-6588. Submitting such a request will not impact what information is collected from you via Tracking Technologies including cookies and tracking pixels, that help us and others better understand you and serve you more relevant content and ads. To opt out of certain Tracking Technologies, click here. Please be aware that every website utilizes its own cookies, so cookie preferences should be set for each SPE website by clicking on the "Cookie Consent Tool" in that website’s footer. If you choose to opt out of any Tracking Technologies such as without limitation cookies and pixels, a preference cookie will be placed on your device in order to honor that opt-out. If you later clear your browser and delete cookies from your device, by doing so you will also remove the preference cookie. Therefore, in order to remain opted out of Tracking technologies, you will have to go back to the Cookie Consent Tool and renew your choices.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
A California consumer has the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA.
Authorized Agent
A California resident may designate an authorized agent to make a request on his or her behalf. To make such a request to delete or to receive information regarding Personal Information that SPE has about you, your authorized agent should submit the request here. To submit an opt-out request, they should click here. They and/or you will be asked to provide proof of such authorization, i.e., a power of attorney or a letter of authorization and proof of identity. We will contact your agent and/or you with additional details after the request has been received.
Personal Information Collected, Sold or Disclosed
SPE may collect the following categories of Personal Information: identifiers such as name, mailing address, online identifier, Internet Protocol Address and telephone numbers; characteristics of protected classifications under California or federal law such as gender or date of birth; commercial information such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; biometric information; internet or other electronic network activity; information such as browser type, operating system, traffic to and from websites; advertising data and other standard weblog information collected via cookies; geolocation data; access-control location data gathered about visitors while on an SPE property; audio, visual, or similar information including without limitation closed-circuit television images of visitors while on an SPE property; inferences drawn from any of the information identified above. This information may be used for the purposes disclosed in this Privacy Policy including to provide services requested, managing accounts including registration and participation in products and services; maintaining and improving SPE sites, products and services; identity resolution, personalizing customer experiences including tailoring content; consumer marketing including push notifications, online and mobile ads, emails, and SMS/text messaging from SPE and other Sony group companies; to maintain security on SPE properties and conduct security screenings to the extent permitted by law; and to satisfy compliance and legal obligations.
SPE may have collected any of the above categories of Personal Information about California residents during the past 12 months for the purposes described in this policy. This information may have been collected from consumers and data resellers such as data management platforms, and the information may have been shared with third parties such as advertising networks, internet service providers, data analytics providers, operating systems and platforms, social networks and Sony group companies which may not share common branding.
SPE may have disclosed or sold any of the above categories of Personal Information to third parties, including Sony group companies which may not share common branding, for a business or commercial purpose in the past 12 months.
SPE does not sell the Personal Information of California residents under 16 years of age without affirmative authorization.
Financial Incentive Programs
In certain instances, such as in the context of SPE’s Wheel Watchers Club (WWC), SPE offers benefits that may qualify as financial incentive programs (FIP) under California law. California consumers who opt in to the FIP may withdraw from the FIP at any time by contacting SPE at SPE_Privacy@spe.sony.com. Participation in an FIP is voluntary. If you choose to participate in an FIP, SPE may retain, use and/or disclose Personal Information it may have collected about you as described in this Privacy Policy, including the information you provide on the registration page when you join the FIP, in exchange for providing you with FIP benefits (in the case of the WWC, such benefits are described here) and as otherwise offered by SPE to FIP members from time to time. SPE does not calculate the value of Personal Information which it collects. Rather, to the extent SPE creates overall value from its FIPs to its business that could be directly or reasonably related to the value of Personal Information it collects from FIP members, SPE makes a good-faith estimate for California residents which could include any costs and commercial benefits reasonably related to the FIPs.
CHANGES TO THIS PRIVACY POLICY
SPE reserves the right to revise and reissue this Privacy Policy at any time. Any changes will be effective upon the posting of the revised Privacy Policy unless otherwise stated in the revised sections. Your continued use of the Service indicates your consent to the Privacy Policy then posted. If you do not agree, discontinue use of the Service and uninstall Service downloads and applications. If you have a subscription to a Service offering, material changes to this Privacy Policy will only become effective with respect to the aspect of that subscription at the end of the then current term unless you otherwise consent.
CONTACT SPE
If you have any questions about this Privacy Policy, please contact SPE here or at Sony Pictures Entertainment Inc. 10202 W. Washington, Jimmy Stewart Building, Culver City, CA 90232 (Attention: Privacy Program, Information Security).
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