PRIVACY POLICY

Privacy Policy for Customers Using Action Cam Movie Creator or PlayMemories Home

Action Cam Movie Creator and PlayMemories Home is hereinafter referred as the "SOFTWARE"
SOFTWARE PRIVACY POLICY


This Privacy Policy explains the following items:
    i.	How Sony Imaging Products & Solutions Inc., ("Sony", "we", "our" or "us") will read, collect, use and/or store information about your use of the SOFTWARE

    ii.	How you can contact us.

Please read this Privacy Policy carefully.

This Privacy Policy is in addition to any other privacy policy that may apply to your interactions with any Sony affiliate, subsidiary, product, software or service.


1.	About the SOFTWARE
The SOFTWARE enables you to easily transfer, organize, view, edit and share images and videos you capture through this SOFTWARE.


2.	Information that the SOFTWARE may collect and communicate to Sony

When you use the SOFTWARE, the SOFTWARE may read and communicate to us, for our collection, use and/or storage, the following types of information for the purposes described below in Section 3 (“Collected Data”):

    Automatic data collection
When you use the SOFTWARE on your PC and connect to the internet, we may collect the following information automatically:

   
    i.	Device information
Information about your digital camera products connected to the SOFTWARE, such as manufacturer name, model name, serial number and version of firmware, and information about your PC, such as the operating system version.

    ii.	Application information
Information about your SOFTWARE, such as the version, country/region code and language, together with a Global Unique Identifier (GUID) that is generated automatically when you install the SOFTWARE on your PC.

    iii.	Usage information
We may collect information about how you use the SOFTWARE, which may be associated with your GUID, such as the date you start using the SOFTWARE and the number of images and videos that are managed by the SOFTWARE.

    iv. 	Digital camera usage information
We may collect information about how you use your digital camera products connected to the SOFTWARE including how you use PlayMemories Camera Apps installed in such products, which may be associated with your GUID.


3.	How Sony uses your information
Sony may retain, use and disclose the Collected Data described above in Section 2 for so long as you use the SOFTWARE, subject to applicable laws, and for the following purposes:

    i.	Service and product provision
To provide you with the services of the SOFTWARE as described above. 

    ii.	Products and services/service development and manufacturing
To assist us with: (1) the development, improvement and manufacturing of new products and services, (2) the development, improvement and introduction of new features and functions for the SOFTWARE and (3) prediction of the demand for products. 

    iii.	Compliance and enforcement
To enforce and ensure compliance with the terms of use for the SOFTWARE and this Privacy Policy.

    iv.	Updates and development
To help the SOFTWARE run better and provide you with updates.

    v.	Advertising and communication
To send you marketing communications, ads and questionnaires regarding Sony’s and/or its affiliates’ products, services or events, which may be targeted and personalized using your information.

    vi.	Support service
To provide you a support service, including repair of your digital camera products or respond to your inquiry (only if you use Sony’s digital camera products with the SOFTWARE)  

    vii.	To retain, use and disclose the information described above in Section 2 with information collected through Sony’s other software (“Related Information”) for the purposes set forth in Section 3 i, ii, iii, iv, v. and vi. Please note that Sony will not use Related Information outside of the original purposes of its collection.

By using the SOFTWARE, you consent to use of the Collected Data as described in Section 2 for the above purposes in accordance with this Privacy Policy. If you do not consent to use of your Collected Data for these purposes, you may not use the SOFTWARE.


4.	Who else has access to your information?
The Collected Data listed above may also be made available to Sony’s affiliates and to third parties, as follows:

    i.	Sony’s affiliates
Collected Data may be shared with other Sony’s affiliates for the purposes of pursuing the activities set forth in Section 3 above.

    ii.	Third party contractors 
The Collected Data may be stored and/or processed by third party contractors of Sony that assist Sony in the provision and operation of the SOFTWARE. 

    iii.	Business transfer 
The Collected Data may be transferred by us as part of a transaction whereby we are transferring all or part of our business to a third party, including to a Sony affiliate, in which case information held by us about our customers will be one of the transferred assets.

    iv.	Compliance 
We may retain, use and/or disclose any of the 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.

5.     Data Retention 
SONY will keep the Collected Data for as long as it is necessary for the relationship with you and the purposes detailed in Section 3 or otherwise permitted or required under applicable law. 
SONY may retain Collected Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Collected Data for specific periods. 

6.	Transfer of your information internationally 	
The SOFTWARE and service are available to users around the world by Sony Corporation, which is located in Japan. The Collected Data will be processed, stored and transferred for the purposes set forth above in Section 3 to countries outside the European Economic Area (EEA) and/or your country of residence, including Japan. The Collected Data will be processed by staff operating outside the EEA and/or your country of residence who work for Sony or for one of our service providers and may be seen by such staff in those countries. Data protection and privacy laws in these countries may not offer the same level of protection as in the EEA and/or your country of residence and you may have fewer legal rights in relation to Collected Data. 

By using the SOFTWARE, you consent to these transfers taking place. If you do not consent to the transfer of Collected Data, you may not use the SOFTWARE.


7.	Security Control Measure 
Although Sony strives to protect Collected Data by implementing security control measures and safeguards, we are unable to guarantee or warrant the security of any information transmitted to us through the SOFTWARE or that we store on our systems or that is stored on our affiliates’ or third party contractors’ systems. 


8.	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 territories. 

The SOFTWARE is a general audience product and is not targeted or intended for children under the age of 16. If you are a parent or guardian that has become aware that your child has provided us with personal information without your consent, you should contact us as indicated below.  We do not knowingly collect information from children.  


9.	Privacy Rights (including California Privacy Rights)
In some countries, including countries in the European Economic Area, you have certain rights with respect to the personal information Sony holds about you. These may include the right to request a copy of the personal information that we hold about you and/or you may request that we correct, amend, delete or block such personal information if it is inaccurate. If you would like to exercise any of these rights, please contact Sony using the appropriate contact details listed below.


10.     Notice to California Residents
If you reside in California, we are required to provide additional information to you about how we 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 2 above, we may collect certain categories of information about California residents that may be considered “personal information” (“CA Personal Information”) as defined by the California Consumer Privacy Act (“CCPA”) for the purposes described in this Privacy Policy, specifically: 
Identifiers: such as device identifiers for your digital camera products connected to the SOFTWARE and your PC, GUID
Internet or other electronic network activity information: such as information of your software (e.g. version, country/region code and language) and usage information of SOFTWARE and digital camera connected to the SOFTWARE.
Sources of CA Personal Information. Consistent with Section 2 above, we may collect CA Personal Information from you or your devices. 

CA Personal Information Disclosed For Business Purposes. 
 - 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, Internet or other electronic network activity information and audio, visual, or similar information.  This information may be shared for the purpose of providing services to you, for legal compliance, or to protect legitimate interests, in compliance with law. 
 - Sale of CA Personal Information: In the preceding twelve months, we have not sold (as defined under CCPA) CA Personal Information.

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; provided that to the extent permitted by applicable law, we may be required to retain some of your CA Personal Information; and (iii) CA Personal Information Disclosed For Business Purposes. Request information about the CA Personal Information we have disclosed for business purposes within the preceding 12 months. 
Exercising other California consumer rights. If you are a California resident and wish to exercise any of these rights or if you have questions regarding the Information collected or shared with third parties, please: (a) contact us as described in the “Contact Information” section below with the specific nature of your request, referencing “Your California Privacy Rights – PlayMemories Home/ Action Cam Movie Creator”; 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, 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 alternative format can do so by emailing us at: privacy@am.sony.com

	
11.	Changes to this Privacy Policy
This Privacy Policy may be updated from time to time.  We will post the revised version with an updated revision date, at http://support.d-imaging.sony.co.jp/pp/pmh/index.html


12.	Contact Information
In accordance with local laws, residents in any country can contact its regional Sony company to (a) request access to information "we" (Sony Corp) maintains about that individual, (b) seek to change such information, (c) withdraw consent he/she previously provided and/or (d) object on legitimate grounds to the processing of such information.

Contact URL: http://www.sony.net/SonyInfo/Support/


Effective date: June 25, 2020
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