Privacy Policy for “Imaging Edge” Applications/Software/Web Services
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 and/or stores the Collected Data (defined as below) regarding your “Imaging Edge” mobile, PC and web applications and/or services listed below (collectively, “Imaging Edge”). It also describes your data protection rights, including a right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 below.
For the purposes of Regulation 2016/679 (the "GDPR") and other applicable privacy regulations where "data controller" is defined, Sony is the "data controller" of your personal data.
“Sony Group Companies” shall mean Sony 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 the Imaging Edge and is in addition to any other privacy policy that may apply to your interactions with any Sony Group Company or any third party, regarding their product, software or service.
1. What personal data do we collect when you use the Imaging Edge
Sony collects data as described below which may include personal information (collectively, the “Collected Data”) related to your use of Imaging Edge.
Information collected through the Imaging Edge
When you use each of the following, Sony will collect the following information respectively:
· Imaging Edge Mobile / Imaging Edge Mobile Plus (“IEM”)
1. Your Universally Unique Identifier (“UUID”) of IEM
2. Your UUID generated and given by Adobe
3. Information about IEM (e.g., software version, installation date, language and country/region settings)
4. Information about your mobile device (e.g., model name, manufacturer’s name, OS version, and language)
5. Information about your camera device connected to IEM (e.g., model name, settings, errors/cautions, operation log including shooting dates/times, mount lens and mount media)
6. Information you provide in response to questionnaires, such as your level of skill as a photographer and the subjects you like to photograph
· Transfer & Tagging / Transfer & Tagging add-on (“TTAD”)
1. Your UUID of TTAD
2. Information about TTAD (e.g., software version, installation date ,language and country/region settings)
3. Information about your mobile device (e.g., model name, manufacturer’s name, OS version, language)
4. Information about photographed images of your camera device transferred to TTAD (e.g., file name, file size and caption data)
5. IPTC preset and user dictionary added or imported by you
· Movie Edit add-on (“MEAD”)
1. Your UUID of MEAD
2. Information about MEAD (e.g., software version, installation date, language and country/region settings)
3. Information about your mobile devices(e.g., model name, manufacturer’s name, and OS version)
· Imaging Edge Desktop (Remote/Viewer/Edit) (“RVE”)
1. Your UUID of RVE
2. Your UUID of Sony’s PlayMemories Home application (if you use it)
3. Information about RVE (e.g., software version, installation date, language and country/region settings)
4. Information about your PC (e.g., CPU,OS version)
5. Information you provide in response to questionnaires (including your level of skill as a photographer and the subjects you like to photograph)
· Imaging Edge Desktop (“IED”)
1. Your UUID of IED
2. Your UUID of RVE (if you use)
3. Information about IED (e.g., software version, installation date, language and country/region settings)
4. Information about your PC (e.g., OS version)
Please note that Sony also automatically receives device and usage information about how you are using and interacting with Imaging Edge, for example: information about which of the Imaging Edge functions you choose to use, picture transfer times and movie recording time.
If you install and use more than one Imaging Edge feature or service on the same device, Collected Data collected through either one will be linked to and analyzed in conjunction with Collected Data collected through the other by using your UUIDs only for the purposes set forth below. Also, if you use Imaging Edge with PlayMemories Home on the same PC, Collected Data collected through the Imaging Edge will be linked to and analyzed in conjunction with Collected Data collected through PlayMemories Home by using your UUIDs solely for the purposes set forth below. Sony may also supplement Collected Data with other data collected about you from third parties.
If you have an Creators’ Cloud Account, your registered account information (Name, Email address, Date of birth, Address (Country/Region and City), Gender and/or Language preferences) will be linked to and analyzed in conjunction with Collected Data only for the purposes set forth below. For more information about Creators’ Cloud Account, please go:
https://acm.account.sony.com/tos_pp?client_id=f5a479d7-70d3-42f9-aa23-dd45144fec8d
2. Purposes and legal basis for processing Collected Data
Contract
Sony processes Collected Data in order to perform its contract with you to provide Imaging Edge.
Consent
Sony processes Collected Data for the following purpose based on your consent.
1. Improving, designing and developing products and services
If you give us consent, Sony will collect and/or analyze Collected Data in order to improve Sony Group Companies’ products and services and to develop new ones, and to predict the demand for those products and services so that we can provide improved user experiences for current and/or future products and services. You can withdraw your consent and stop our use of the Collected Data for Improving, designing and developing and products and services at any time by Menu＞Privacy settings.
2. Latest Sony news and recommendations for you
Tailored news, offers, and recommendations via notifications
If you give us consent, we will use Collected Data to provide you tailored Sony news, offers, and recommendations that maybe of interest to you via notification function of your Imaging Edge. You can withdraw your consent and stop our use of the Collected Data for customized notifications at any time by Menu＞Privacy settings.
Sharing information with your local Sony office
In addition if you reside in Europe, Sony will share the Collected Data with its local Sony office which may send you emails and provide you with news, offers, and recommendations regarding Sony products, services and other offerings that may be of interest to you. If you give us consent on sending you emails at any Sony service including Sony account (Imaging Edge), you will receive emails from local Sony office. For more information on the privacy practices of our local Sony office, click here: SEU Privacy Policy
You can unsubscribe from receiving email marketing from local Sony office at any time using the “unsubscribe” link in such email or contacting us as described in Section 10 below.
Legitimate Interest
Sony also processes Collected Data in order to pursue its legitimate interests in:
1. Protecting Sony Group Companies and the Imaging Edge users
Sony may collect and/or analyze Collected Data in order to identify potential security threats and to protect Sony, Sony Group Companies and the Imaging Edge users.
2. Providing certain information and service related to your Sony digital camera product
If you use Sony digital camera product with Imaging Edge, Sony will use Collected Data in order to provide you with information regarding your Sony digital camera product and for support services including repair of your digital camera product and response to your inquiry.
Where applicable, we have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.
As required by law
We also process Collected Data where required to do so by applicable law, for example in response to requests by government or law enforcement authorities conducting an investigation.
3. Who else has access to Collected Data?
Collected Data that is communicated to and stored by Sony will be made available to other Sony Group Companies and to third party as follows:
Sony Group Companies and third party contractors
We will share Collected Data with Sony Group Companies, which locally sell and provide our products and services, solely for the purposes set forth above.
In addition, we will share Collected Data with Amazon Web Services who provides data back-up service to us, and which is located in the US. This contractor is engaged for the purposes of pursuing the activities outlined in this Privacy Policy on Sony’s behalf, acting as processors of Sony.
Google Services
The Imaging Edge uses Firebase Crashlytics, a service provided by Google Inc. (“Google”) and the TTAD also uses Google Speech-to-text API, an API provided by Google. Firebase Crashlytics will track, prioritize and fix stability issues that erode quality of the Imaging Edge you use, and Google Speech-to-text API will be used for voice-input function of the TTAD. To better understand how Google uses the information it receives, visit: https://policies.google.com/privacy.
Adobe Analytics
The IEM uses Adobe Analytics, a service provided by Adobe Systems Incorporated ("Adobe"). Adobe Analytics will analyze how you use the IEM after turning your IP address into non-recognizable strings. To better understand how Adobe uses the information it receives, visit: https://www.adobe.com/privacy/policy.html.
Business transfer
In the event that we sell or transfer a portion or all of our business, Collected Data may be transferred by us to the purchasing or acquiring entity as part of the transaction. In the event we sell or transfer Collected Data to a purchasing or acquiring entity you will be duly informed.
Compliance and enforcement
We will retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.
4. Data Retention, Managing Collected Data
We will continue to retain Collected Data for as long as we continue to make the Imaging Edge available to customers, and for a further 6 months following discontinuation, at which point the information will either be anonymized or destroyed. Please note that we may be required to retain certain information by law.
5. International Transfer of Collected Data
Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan and the US. Collected Data will be processed by staff operating outside the EEA and/or your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries.
Sony takes appropriate measures to ensure that all transfers of Collected Data from the EEA to countries outside the EEA meet the requirements of applicable EU data protection legislation. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. If you have any questions or concerns about Sony's data transfer arrangements, please contact us using the details at Section 10 below.
6. Security
Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of Collected Data. Although we strive to protect Collected Data, we cannot guarantee or warrant the security of any information transmitted to us through your Imaging Edge or that we store on our systems or that is stored on our third party contractors’ systems.
7. Our Policy Regarding Children
Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, including the Children's Online Privacy Protection Act in the United States and applicable local legislation in other countries. Imaging Edge 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 below.
8. Privacy Rights (including the EEA )
In some countries, including countries in the EEA, you have certain rights with respect to the personal information Sony holds about you. These may include rights to: request a copy of the personal information that we hold about you, and/or you may request that we correct, amend, delete the Information if it is inaccurate. In some countries, including countries in the EEA, you may also ask us to provide some types of the Information to you in a structured, machine readable format and ask us to share (port) such data with another controller. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete Information which we are required by law to keep or have compelling legitimate interests in keeping. If you would like to exercise any of these rights, please contact us as described in Section 10 below.
9. Changes
This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (whenever necessary under the applicable law) of any changes to this Privacy Policy through the Imaging Edge.
10. Contact Information
FOR RESIDENTS IN THE EU:
If you have any questions or concerns about this Privacy Policy or if you wish to exercise any legal right you have in respect of Collected Data, please contact Sony Europe BV, who is Sony’s representative in the EU, at:
You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom, or you can contact your local Sony Group Companies at http://sony-europe.com.
FOR RESIDENTS IN THE UK:
You can also get in touch by writing to Sony Europe BV, The Privacy Office, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.
FOR RESIDENTS IN OTHER COUNTRIES OR REGIONS:
If you have any concerns about how we process your data, you can find our contact details below or on the website of your local Sony Group Companies at:
Africa, Middle East and CIS countries: http://www.sony-asia.com/countryselector.html
If you are not satisfied with how we have handled your questions or concerns, or have any complaints about how we process Collected Data, you have the right to complain to the local data protection supervisory authority in the place where you live or work or in the place where you believe a breach may have occurred.
Last Updated: 2023-02