Privacy Policy for “Creators’ Cloud”

 

Last Updated: 2024-12

 

This Privacy Policy sets out how Sony Corporation, of 7-1 Konan 1-chome, Minato-ku, Tokyo 108-0075, Japan (“Sony”, “we”, “our” or “us”) collects, uses, stores and otherwise processes the Collected Data (defined below) in relation to our “Creators’ Cloud” web applications, Creators’ App mobile applications and Creators’ Cloud’s features such as Discover or other offerings which link to this Privacy Policy (collectively, “Creators’ Cloud”). It also describes your data protection rights, including the 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 “Privacy Rights” below.

 

We also may provide you with additional information when we collect Collected Data, where we feel it would be helpful to provide relevant and timely information.

 

For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of "controller" and “processor” are defined, Sony is the "controller" of the Collected Data described in this Privacy Policy .

 

Sony Group Companies” means Sony Group Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony Group 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).

 

This Privacy Policy only applies to Creators’ Cloud and is in addition to any other privacy policy or privacy notice that may apply to your interactions with any Sony Group Company or any third party regarding their products, software or services.

 

We have provided some additional information for individuals located in the European Economic Area (“EEA”) and the UK (together, “EEA/UK Individuals”).

 

Table of Contents

1.    What personal information we collect

2.    Why we process personal information

3.    How we share your personal information

4.    How long we retain your personal information

5.    International transfers of personal information

6.    Security

7.    Children

8.    Privacy rights

9.    Changes to this Privacy Policy

10.  Contact Information

11.  Miscellaneous

 

 

1.     What personal information we collect

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

 

l  Information to identify you and other personal identifiers

This includes information such as:

-              If you have a Sony Account (Creators’ Cloud), your log-in information and registered account information (including email address, date of birth, address (country/region/city) and language preferences). For more information about Sony Account (Creators’ Cloud), please go to Terms/Privacy (sony.com);

-              Your universally unique identifier (UUID) for Creators’ App and your account ID for Sony Account (Creators’ Cloud); and

-              Your Discover profile information (including your icon/profile picture, nick name and self-introduction) and account information for third party platforms that you provide, project access numbers and settings.

 

l  Information relating to your Creators’ Cloud contract and purchases

This includes information such as the terms you entered into, the information we have provided you in relation to our services, service communications and information about the services you have obtained from us and from resellers of our services (as further explained in Section 3 How we share your personal information”).

 

l  Information related to contact and support interactions with us

This includes any contact with our customer services team, and we may collect additional information from you via calls, chat, text or other means, some of which may be recorded.

 

l  Information we collect automatically about your use of Creators’ Cloud

This includes information such as:

-              Which pages you visit, which content you view and what links and buttons you click

-              The operation log of each function and usage information such as settings, shooting equipment and utilization volume and

-              In relation to Discover, interaction information such as the number of account followers, people you follow, likes and search terms and history.

 

l  Information we collect automatically about devices used to access Creators’ Cloud and your settings

This includes information such as:

-              IP address, operating system (“OS”), browser and browser version (in relation to our web services);

-              Your IP address, software version, installation date and operation logs (in relation to Creators’ App);

-              Mobile device model name, manufacturer’s name, OS version, language and device ID (in relation to Creators’ App); and

-              Country/region settings, language, color theme (light/dark) of browser and operating system.

 

l  Information about the camera devices you use with Creators’ Cloud

This includes information such as:

-              Serial number, model name, settings, errors/cautions;

-              Operating logs including shooting date/times, mount lens and mount media; and

-              Licensing information for adding functions to the camera devices.

 

l  Information about content uploaded to Creators Cloud

We process the content that you upload to Creators’ Cloud on your behalf subject to our [TERMS OF USE FOR CREATORS’ CLOUD], including geolocation metadata that may be attached to the content. In addition, we collect and process information related to your content such as:

-              metadata relating to your content, such as file name, camera name, lens name, shooting date/times, ratings and length of video;

-              Information you provide or post in relation to your content (e.g. genres, hashtags and comments in the case of Discover); and

-              The level of interaction with your content on Discover (e.g. number of likes and number of views).

 

We also process the content that you upload to Creators’ Cloud as necessary for content moderation purposes. If the content includes data which is treated as a “special category” – for example, data that shows someone’s racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, data concerning health or a person’s sex life of sexual orientation – then we will process special category data, on behalf of the user who uploaded such information.

 

l  Information related to advertising and marketing and preferences

This includes information such as your marketing preferences, your interaction with our advertising and your participation in any offers or promotions. It also includes questionnaire and survey responses.

 

l  Crash and error information

This includes error and crash information collected through Google Crashlytics and error information about your wi-fi connection.

 

l  Cookies

Sony and third parties use cookies and similar technologies across Creators’ Cloud. Please see our Cookie Policy on the Creators’ Cloud website for further information.

 

We collect most of this information from you directly. For example, data is collected from forms completed by you on Creators’ Cloud, from correspondence with you and from information you provide in response to questionnaires or surveys from Sony.

 

We also collect information about you from other people or organisations. In cases where we review content uploaded to Creators’ Cloud, the information in such content will have been provided by the user that has uploaded the content, or by the person who flagged the content for review. We collect information about your purchases from resellers such as cleverbridge (as further explained in Section 3 “How we share your personal information”).

 

Collected Data may be linked and analysed in conjunction with the data we collect through other Sony products and applications if you use one of those.

 

2.     Why we process personal information

Sony processes your Collected Data for the purposes listed hereafter:

 

l  Provision of products and services under the contract you have with us

Sony processes Collected Data in order to perform its contract with you to provide Creators’ Cloud and other services linked to Creators’ Cloud where applicable. This includes:

-              Managing the customer relationship;

-              Responding to inquiries and providing customer support;

-              Sending necessary communications; and

-              Confirming payment.

 

For EEA/UK Individuals: The legal basis for the processing above is the performance of the contract that we have with you.

 

l  Our legitimate business interests as set out below

-              Providing explore and recommendation features in Discover

Sony processes information relating to user accounts, followers, likes, bookmarks and information relating to content (e.g. genres and hashtags) to allow other users on Discover to explore content and to enable Sony to recommend content that may be of interest to you.

-              Protecting the interests of Sony Group Companies and Creators’ Cloud users

Sony processes information in order to protect the Sony Group Companies, their business interests and legal rights and Creators’ Cloud users. This includes the use of Collected Data in connection with legal claims, compliance, regulatory, auditing, investigative purposes (including disclosure of such information in connection with legal process or litigation). Sony may process information to create a list to identify such a user of Creators’ Cloud who has breached or is reasonably suspected to have breached our terms, policies, including any other terms of service the user has agreed to and any rules or codes of conduct applicable to the user’s use of Creators’ Cloud.

-              Content Moderation

Sony cannot moderate the whole content in Creators’ Cloud and makes no commitment to do so. However, we will review any complaints we receive about content in Creators’ Cloud and reserve the right in our sole discretion to monitor (including through the use of technology that automatically detects images, text and URLs that breach our terms) users’ content throughout Creators’ Cloud and to remove and/or delete any content. We may use the information we collect (as described above) to detect breaches and enforce our terms, policies, including any other terms of service you have agreed to and any rules or codes of conduct applicable to your use of Creators’ Cloud and to prevent and detect unlawful acts and to safeguard children or other individuals at risk.

-              Managing security or technical issues

Sony processes information in order to detect, prevent, address and analyse security or technical issues in relation to our website, app and services.

-              Providing certain information and services related to your Sony digital camera product

If you use a Sony digital camera product with Creators’ Cloud, Sony will use Collected Data in order to provide you with information regarding your Sony digital camera product such as firmware update information and for support services including repair of your digital camera product and to respond to any inquiry.

-              Undertaking mergers, acquisitions, reorganizations or disposals

 

For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for Sony’s legitimate interests as described above.

 

l  Compliance with law

Sony processes Collected Data in order to comply with applicable law and regulations, this includes responding to requests from and, where required, reporting content to government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws.

 

For EEA/UK Individuals: The legal basis for the above is that the processing is necessary for compliance with a legal obligation, including obligations under the E-Commerce Directive (as implemented into member state & UK domestic law), the Digital Services Act, the Directive on Copyright in the Digital Single Market and the Geo-blocking Regulation. With regard to special category data processed for content moderation purposes the legal basis is compliance with a legal obligation. In relation to the relevant condition to process special category data in the context of content moderation this is public interest associated with the provision of Creators' Cloud on the basis of the EU laws mentioned above and in the UK also for the prevention and detection of crime or the need to safeguard children and vulnerable individuals.

 

l  Product / service development and improvement and analytics

If you give us consent, Sony collects and analyses Collected Data in order to improve Sony Group Companies’ products and services, to develop new ones, to predict the demand for those products and services so that we can provide improved user experiences for current and/or future products and services and to help us develop our advertising and marketing strategies. We may also use Collected Data to help us determine what kinds of products and services you might be interested in.

 

For EEA/UK Individuals: The legal basis for the above is your consent where we have obtained your consent for such activities. Where the activities are not consent-based, the legal basis is our legitimate interests in marketing and promoting our business.

 

l  Providing news, offers, recommendations and surveys

With your consent where required:

-              We use Collected Data to provide you with Sony news, offers, surveys and recommendations that may be of interest to you via the notification function of your Creators’ Cloud applications and push notifications on your device or across the internet.

-              If you are located in Europe, we will share Collected Data with the local Sony office who will send you emails with news, offers, and recommendations regarding Sony Group Company products, services and other offerings. For more information on the privacy practices of your local Sony office, click here: SEU Privacy Policy.

-              We use Collected Data to send voluntary questionnaires and surveys from time to time (for example, in relation to your level of skill as a photographer and the subjects you like to photograph).

 

You can manage your preferences (including withdrawing consent) and stop marketing notifications at any time through the Privacy Settings in the Menu function. You can unsubscribe from receiving email marketing at any time using the “unsubscribe” link in such email or contacting us as described in Section 10 below.

 

For EEA/UK Individuals: The legal basis for the above is your consent where we have obtained your consent for such activities. Where the activities are not consent-based, the legal basis is our legitimate interests in marketing and promoting our business.

 

3.     How we share your personal information

         We share Collected Data with third parties as follows:

 

l  Sony Group Companies

We share Collected Data with Sony Group Companies to the extent such sharing of data is necessary to fulfil a request you have submitted and/or for customer support, marketing, technical operations, event registration or account management purposes.

l  Third-party contractors

We share Collected Data with third-party contractors who provide services such as IT and system administration and hosting, credit card processing, research and analytics, moderation and safety assistance, marketing and customer support for the purposes described in Section 2 above.

l  cleverbridge

Creators’ Cloud uses cleverbridge as a reseller of the services to provide a pricing, billing and payment processing platform. If you purchase the paid service of Creators’ Cloud from cleverbridge, cleverbridge and Sony respectively share your personal data for the purposes of verifying payment and granting you a license to use Creators’ Cloud.

 

Where cleverbridge collects information from you directly, cleverbridge will be the controller of such information. For more information about how cleverbridge processes your personal data, please refer to cleverbridge’s privacy policy available here: https://www.cleverbridge.com/?scope=opprivacy.

 

l  Business transfer

In the event that we undertake a merger, acquisition, reorganization or disposal, Collected Data may be transferred to the purchasing or acquiring entity as part of the transaction.

l  Government authorities, law enforcement officials, regulators, courts and similar

We share Collected Data with government authorities, law enforcement officials, regulators, courts and similar for the purposes described above in Section 2.

l  Professional advisers

In individual instances, we may share Collected Data with professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.

 

4.     How long we retain your personal information

We retain Collected Data for as long as we continue to make Creators’ Cloud 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 transfers of personal information

Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy from your country/regions of residence to countries/regions outside your country/region of residence, including Japan, the US and Vietnam. Collected Data will be processed by staff operating outside your country/region of residence who work for us or for one of our service providers, including in the locations set out in Section 3 “How we share your personal information” above. Some of the countries and regions may not provide the same level of data protection as your country.

 

For EEA/UK Individuals: Sony takes appropriate measures to ensure that all transfers of Collected Data to outside of the EEA/the UK meet the requirements of applicable EU and UK data protection legislation.

Where information is transferred outside the EEA and the UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the UK Government, the personal data is adequately protected by the vendor's EU / UK Processor Binding Corporate Rules, the EU Commission’s approved standard contractual clauses which can be accessed here or the addendum to the EU Commission’s standard contractual clauses or standalone international data transfer agreement approved under UK data protection law (as applicable). A copy of the relevant mechanism can be obtained for your review on request by using the contact details 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 Creators’ Cloud or that we store on our systems or that is stored on our third-party contractors’ systems.

 

7.     Children

Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children. Creators’ Cloud is not directed to and does not knowingly collect personal information from children under the age of 16. Depending on your country/region of residence, this threshold age for a child may differ. 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 “Contact Information” below.

 

8.     Privacy rights

In some countries, you have certain rights with respect to the Collected Data Sony processes about you. These may include the right to request a copy of the Collected Data that Sony holds about you and/or you may request that Sony corrects, deletes, blocks/restricts processing of such Collected Data. You may also object to Sony’s processing of Collected Data. In some countries, you may also ask us to provide your Collected Data to you in a structured, machine-readable format and ask us to share (port) such data with another organisation. These rights may be limited, for example, if fulfilling your request would reveal Collected 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 “Contact Information” below.

 

If you are not satisfied with how we have handled your questions, concerns or have any complaints about how we process Collected Data, you have a right to lodge a complaint with a data protection supervisory authority.

 

Where we collect Collected Data to administer our contract with, this is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of the requested Collected Data is optional, but this may affect your ability to use the services or use particular aspects of the services where the information is needed for those purposes.

 

For EEA/UK Individuals:

You have the right to:

-        Ask Sony for a copy of your personal data

-        Correct, delete or restrict processing of your Collected Data

-        Obtain the Collected Data you provide in a structured, machine-readable format

-        Object to the processing of your Collected Data in some circumstances (in particular, processing for the purposes of direct marketing and where we do not have to process the data to meet a contractual or other legal requirement) and

-        Where we have asked for your consent, withdraw consent at any time. If you ask to withdraw your consent to Sony processing your information, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal information 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.

9.     Changes to this Privacy Policy

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

 

10.   Contact Information

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, you can contact local Sony Group Companies using the contact details that can be found at https://www.sony-europe.com/.

For EEA/UK Individuals:

Sony’s representative in the EU is Sony Europe BV that can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to to its business address at Taurusavenue 16, 2132LS Hoofddorp, the Netherlands.

 

Sony’s representative in the UK is the UK branch of Sony Europe BV who can be contacted at privacyoffice.seu@sony.com. You can also get in touch by writing to Sony Europe BV (UK branch), The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.

 

11.   Miscellaneous

         11.1       Sending Location Information to Camera Devices

If you give us consent, Creators' App will obtain the location information of the mobile device on which it is installed and send the location information to the camera device used with it. It will collect this location information whether the app is in an active or inactive state. This location information will be added to the metadata of the content captured by the camera device as the location information of that content. Please note that this location information is not sent to Sony.

 

         11.2       Using YouTube service

(1)       Creators' App uses YouTube API Services to stream contents on YouTube. If you use the network streaming function of Creators' App to connect the camera device to the internet and stream the content captured by the camera device on the YouTube service, the following information will be exchanged between Creators' App or the camera device and Google LLC for the execution of the streaming. Your use of YouTube service is subject to the privacy policy of Google LLC, which can be found here:

           http://www.google.com/policies/privacy

(a)       Information received from Google LLC:

1)      Authentication tokens (access token and refresh token)

2)      Broadcast ID

3)      Information for streaming (stream URL and stream key)

(b)       Information sent to Google LLC:

1)      Content to be streamed

2)     Metadata of the content to be streamed (title, description, scheduled publication date and time, publication range, whether it is released to children, etc.)

(2)       The information received from Google LLC as specified in (1)(a) above can be deleted from the settings screen of Creators' App or the camera device where the information is stored. Additionally, you can disable access from Creators' App or the camera device through the following Google LLC security settings page:

https://security.google.com/settings/security/permissions

(3)       Creators’ App’s use and transfer of information received from Google LLC as specified in (1)(a) above to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

 

         11.3       Using of Google Drive Service

(1)       When you link Creators' Cloud with the Google Drive service and transfer content from Creators' Cloud to the Google Drive service, Creators' Cloud will use the Google Drive API services to exchange information with Google LLC as follows for the execution of this linkage. Your use of Google Drive service is subject to the privacy policy of Google LLC, which  can be found here:

           http://www.google.com/policies/privacy

(a)       Information received from Google LLC

1)      Authentication tokens (access token and refresh token)

2)      Information of the Google account using the linked Google Drive service (name and email address)

3)      List of folder names on the destination Google Drive service

4)      Usage status of the destination Google Drive service (storage capacity and current usage)

(b)       Information sent to Google LLC

1)      Content to be transferred

2)      Metadata of the content to be transferred

(2)       The information received from Google LLC as specified in (1)(a) above can be deleted from the settings screen of Creators' App or the camera device where the information is stored. Additionally, you can disable access from Creators' App or the camera device through the following Google LLC security settings page:

https://security.google.com/settings/security/permissions

(3)       Creators’ App’s use and transfer of information received from Google LLC as specified in (1)(a) above to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

(4)       The information received from Google LLC as specified in (1)(a) above will not be used to develop, improve, or train generalized AI and/or ML models.

 

         11.4       Using of Adobe Lightroom Service

(1)       When you link Creators' Cloud with the Adobe Lightroom service and transfer content from Creators' Cloud to the Adobe Lightroom service, Creators' Cloud will use the Adobe Lightroom API services to exchange information with Adobe Inc. as follows for the execution of this linkage. Your use of Adobe Lightroom service is subject to the privacy policy of Adobe Inc., which can be found here:

           https://www.adobe.com/go/privacy

(a)       Information received from Adobe Inc.

1)      Authentication tokens (access token and refresh token)

2)      Information of the Adobe account using the linked Adobe Lightroom service (name and email address)

3)      List of folder names on the destination Adobe Lightroom service

4)      Usage status of the destination Adobe Lightroom service (storage capacity and current usage)

5)      License information for the destination Adobe Lightroom service

(b)       Information sent to Adobe Inc.

1)      Content to be transferred

2)      Metadata of the content to be transferred

(2)       The information received from Adobe Inc. as specified in (1)(a) above can be deleted on the settings screen of Creators' Cloud where the information is stored, and you can also disable access from Creators' Cloud on the following Adobe Inc. security settings page:

           https://account.adobe.com/privacy