PRIVACY AND COOKIES POLICY

Effective Date: This Privacy and Cookies Policy is effective as of 11/8/2021.

This Privacy and Cookies Policy, subject to applicable law, applies to any Sony Pictures Entertainment Inc. 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 Sony Pictures Entertainment Inc. and its subsidiaries. To find the local SPE entity in your jurisdiction, please click here. Sony Pictures Entertainment Inc.’s corporate offices are located at 10202 West Washington Boulevard, Culver City, California 90232 USA.

KEY POINTS

1. Information you provide

We collect certain categories of Personal Data you provide to us.

2. Information from third parties

We receive certain information about you from third parties, such as third-party applications and data providers.

3. Use of your information

We use personal data 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, our television programs, and other offerings.

4. Cookies and similar technologies

We use cookies and other tracking technologies to personalize Content and advertising and to make our Content function better.

5. Sharing your information

We disclose your personal data publicly when you post user-generated content via our sites or apps. We may disclose personal data with our business partners or other Sony group companies in accordance with applicable law. We also share data with third parties we engage to process data on our behalf or when such sharing is required by law, or in certain other situations.

6. International transfers

We transfer your personal data to the United States or other jurisdictions in which we or our service providers are located.

7. Your rights

Subject to applicable law, you may have certain rights, such as requesting access, rectification, deletion, or other actions regarding your personal data.

8. Data security

We maintain technical and organizational measures to protect personal data from loss, misuse, alteration, or unintentional destruction.

9. Other important issues

We provide other information in this Privacy and Cookies Policy about: (i) the legal basis for collecting and processing personal data, (ii) the consequences for not providing personal data, (iii) automated decision-making, and (iv) data retention.

10. Changes to this policy

We may revise this Privacy and Cookies Policy, for example, to reflect changes in the law, our personal data collection and use practices, the features of the Content, or advancements in technology.

11. Contact us

Should you have any questions, concerns or comments, please contact us as detailed below.

  1. INFORMATION YOU PROVIDE

We may collect the following categories of personally identifiable information (“Personal Data”) you provide to us when using the Content:

  1. Identification Data: Information that allows us to differentiate you from other individuals. This may include: name and surname, date of birth, gender, postal address, and password.

  2. Contact Information: Information that allows us to keep in touch with you. This may include: email address and phone number.

  3. Electronic Records: This information includes certain data from you or your device that are obtained when you access our Content.

  4. User-Generated Content: We may also collect information that you provide to us through our Content, such as photographs, video images or other content that you may upload.

  5. Usage Information: We and our third-party partners and service providers, such as Google Analytics and/or Adobe Analytics, may use a variety of technologies that collect and provide information about how the Content is accessed and used. Usage Information may consist of your internet browser type and version, operating system, service provider, the webpages and apps you viewed, the time you viewed them and for how long, game history and skill level, demographic information about you (such as your age, gender, language, location and interest areas, where available), your location, time zone, language, and what webpages you looked at before viewing the current page.

  6. Device Identifiers: We may also automatically collect your IP address or other unique identifier for the computer, mobile device, technology or other device you use to access the Content. A unique identifier is a number that is automatically assigned to your device when you access a web site or its servers, and our computers identify your device by this number. Some mobile service providers may also provide us with the physical location of the device used to access the Content.

  1. INFORMATION WE RECEIVE FROM THIRD PARTIES

The Content may include hyperlinks in association with the Content, 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 Data from you. Their privacy policies apply in such cases, and not this Policy.

Certain functionalities on the Content permit interactions that you initiate between the Content 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 Content and a Third-Party Service; “liking” or “sharing” SPE’s content; logging in to the Content using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Content to a Third-Party Service (e.g., to pull or push information to or from the Content). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Content or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Content (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 Content 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 Content and any Third-Party Service.

  1. HOW WE USE YOUR INFORMATION

We use the categories of Personal Data outlined above for the following purposes:

  1. To fulfil a contract, or take steps linked to a contract;

    1. To process your registration on a site or app, or entry into a competition, prize draw or contest

    2. To send you information about changes to our terms or policies and other transactional messages

    3. To process your payment and fulfil your purchased order or subscription service

    4. To create or administer your online account or subscriptions

  2. Where this is necessary for purposes which are in our, or third parties’, legitimate interests. These interests are:

    1. To provide you with access to Content and features in the sites and apps

    2. To send you information you have requested

    3. To ensure the security of our sites and apps, by trying to prevent unauthorized or malicious activities

    4. To enforce compliance with the Terms of Use posted in association with this Policy and other policies and to help other organizations (such as copyright owners) to enforce their rights

    5. To determine your approximate location and adapt our Content (e.g. language, currency, territory restrictions)

    6. To tailor Content, advertisements and offers for you, including providing you with personalized Content in the context of our streaming services

  3. Where you give us consent:

    1. Where you ask us to send marketing information to you via a medium where we need your consent (for example, email marketing)

    2. Where required by applicable law, consent to place cookies and to use similar technologies

    3. On other occasions where we ask you for consent, for a purpose which we explain at that time

  4. For purposes which are required by law:

    1. Where we need parental consent to provide online services to children (as defined by each jurisdiction) or the relevant age below which parental consent is required. However, most of our Content is not designed to be accessed by children.

    2. In response to requests by government or law enforcement authorities conducting an investigation.

  1. COOKIES AND SIMILAR TRACKING TECHNOLOGY

Cookies, web beacons (also known as "tracking pixels") 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 emails, 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 perform several different functions, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.

We use tracking technologies for three purposes:

  1. To provide you with the service you have requested: for example, keeping you logged in during your visit and ensuring security of the Content.

  2. To show adverts that are more relevant to your interests: for example, with your consent, we use tracking technologies to remember Content that has interested you and then use this to help us serve more relevant ads to you, including when you are on another site. Tracking technologies also help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed. We also allow other organizations to use tracking technologies for these advertising purposes too. To learn more about certain cookies used for interest based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings.

    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 in this Policy and as described below.

  3. 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, Google, and others to help us analyze and improve your browsing experience as outlined in this paragraph. 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, and for other analytics services follow the instructions below.

How to manage tracking technologies

If you are using our Content via a browser and cookies are deployed, you can change your cookie preferences and withdraw your consent at any time using the . You do not need to have cookies enabled to use our Content, but turning them off may affect your experience on our sites and apps.

In addition: (1) 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; and (2) you can opt-out of analytics as described above.

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

Subject to applicable laws, we may use GPS (global positioning systems) software, geo-filtering and other location-aware technologies to locate (sometimes precisely) 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 precise geo-location tracking through the location settings on your device and/or in our Content (if available).

PlayStation, Apple iOS, Android Devices, and Other Connected Devices

By accessing certain applications from these devices, you consent to cookies and other technologies being stored to your device for the following purposes: keeping you logged in, managing parental control PINs, analytics and advertising. These cookies are essential to the operation of the application. Depending on which device you are using, you may be able to opt out or remove these cookies from the device through the settings or by deleting the application or your account.

  1. HOW WE SHARE YOUR PERSONAL DATA

We may share your Personal Data in the following circumstances:

  1. With your consent. If we ask you for consent to share your Personal Data with third parties for their own marketing purposes, and if you give consent, we will share Personal Data with these third parties. We do not share your Personal Data with third parties for their own marketing unless you agree. You also may specifically request, sometimes through your use of an interactive feature, a widget or an application, that we share your Personal Data with a third party and we will typically do so under those circumstances. In addition, if you choose to register for a promotion, such as a competition, prize draw or contest, your Personal Data may be disclosed to third parties for purposes of the administration of such promotion. This may also mean that your Personal Data will be included on a winners list or best placed. If you submit user-generated content to a site or app, this content will be disclosed publicly.

  2. Third Parties Providing Services on Our Behalf. We share data with our business partners, as well as third parties who perform functions on our behalf, such as hosting or operating our site and apps, sending emails, and carrying out data analysis. Where you make a purchase on one of our sites or apps, we will share your Personal Data with third parties to process your card payment and deliver your order.

  3. Affiliate Sharing. We share your Personal Data with other SPE entities which are involved when we process data for the purposes listed above. We may also share your Personal Data with other Sony group companies for analytics purposes and for direct marketing purposes in accordance with applicable law. The entity responsible for management of Personal Data shared pursuant to this section is listed here.

  4. Business Reorganization. SPE or any of its assets, including the Content, may be sold, or other transactions may occur in which your Personal Data may be considered one of the business assets of the transaction. In this case, your Personal Data may be transferred to the purchaser or prospective purchaser to the extent permitted by law, either as part of the transaction or during any due diligence process.

  5. Mandatory Disclosures and Legal Protections. We 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, to verify or enforce our Terms of Use posted in association with this Policy or where this is necessary for us or for third parties to protect our or their rights, property, safety, or security.

  1. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Our Content is hosted and operated by us or our service providers in the United States and other countries. As such, your Personal Data will be transferred to and processed in the United States and other countries that may not provide the same level of data protection as your home country. We provide appropriate protections for international transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area (“EEA”), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. Where your consent is required by applicable law, by using the Content and providing us with your Personal Data, you consent to the international transfer of your Personal Data.

  1. YOUR RIGHTS

Where required by applicable law, you may have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal). In particular, you may ask us not to use your Personal Data when we carry out profiling for direct marketing purposes or any other processing based on your consent.

Please visit this page in order to submit a request to exercise your applicable rights and to contact us with general privacy-related questions. We may request certain information for the purpose of verifying the identity of the individual seeking access to his or her Personal Data.

We will make good-faith efforts to make such requested changes in our then-active and relevant consumer databases as soon as practicable, but it is not always possible to immediately completely change, remove or delete all your information or public postings from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain your Personal Data (a) as permitted by applicable law; (b) as required by applicable law; and (c) for so long as reasonably necessary to fulfil the purposes for which the data is retained except to the extent prohibited by applicable law.

You can opt out of receiving email newsletters 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.

  1. DATA SECURITY

We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Data. If you have reason to believe that your interaction with us is no longer secure please contact us immediately as detailed in the following “Contact Us” page.

  1. OTHER IMPORTANT ISSUES
  1. Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping); (c) consent (where you have provided consent as appropriate under applicable law); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Content).

  2. You are not required to provide all Personal Data identified in this Privacy and Cookies Policy to use our Content or to interact with us offline, but certain functionality will not be available if you do not provide certain Personal Data. If you do not provide certain Personal Data, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

  3. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

  4. For Personal Data that we collect and process for other purposes described above, we typically retain such Personal Data for no longer than the period necessary to fulfil the purposes outlined in this Privacy and Cookies Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations. We generally retain Personal Data related to marketing activities for the time period permitted by applicable law, and upon request we will securely delete such data in accordance with applicable law.

  1. CHANGES TO THIS POLICY

We may update this Privacy and Cookies Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy and Cookies Policy is posted above, and we encourage you to visit our Content periodically to stay informed about our privacy practices. We will post the updated version of the Privacy and Cookies Policy on our Content, and ask for your consent to the changes as required by applicable law.

  1. CONTACT US

If you have any questions or comments regarding this Privacy and Cookies Policy or our privacy practices, please contact us by clicking one of the options here or write to us at the relevant address of the entity listed here.

You may also have a right to submit a complaint to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred.