SONY MEDIA CLOUD SERVICES PRIVACY POLICY

Last Revised: December 19, 2014

IMPORTANT NOTICE–PLEASE READ CAREFULLY. THIS PRIVACY POLICY DESCRIBES THE POLICIES OF SONY MEDIA CLOUD SERVICES LLC (“SONY MCS,” “WE,” “US,” OR “OUR”) FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION IN CONNECTION WITH YOUR USE OF OUR WEBSITE AND SERVICES. WE ENCOURAGE YOU TO REVIEW THE ENTIRE PRIVACY POLICY.

Sony MCS values your privacy and believes you have a right to know what type of information we may collect when you interact with us and/or use our products, and our practices with respect to that information. This privacy policy (the “Privacy Policy”) governs your access to our websites www.sonymcs.com, www.cithebigpicture.com, www.cimediacloud.com, and workspace.cimediacloud.com as well as our services, products and related software and toolset, all of which are presently marketed under the trademark Ci (pronounced “see”) (collectively, “Ci”). This Privacy Policy describes the information we collect through your use of Ci and the manner in which it may be used by Sony MCS, our agents, subsidiaries, trusted partners and affiliates acting on our behalf.

By using Ci you expressly consent to the information practices described in this Privacy Policy. Our Privacy Policy is intended to assist you in making informed decisions when using our website and services. Please take your time to read and understand the policy.

Notwithstanding the foregoing, all information and data submitted through any third party website or application will also be subject to such third party’s privacy policy and not ours.

To help protect you and others, we monitor use of our website, and use the information we collect, including personally identifiable information, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of our website; ensure compliance with the applicable terms of service and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of Sony MCS, its partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through our website. If you do not consent to these conditions, you must discontinue your use of Ci.

1. Information We Collect.

Information You Provide. When you register for an account we may collect some personal information such as your name, email address, password, company, address, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information)(“Personal Information”). We may also collect information in connection with your use of our sharing and collaboration features such as the email addresses for your contacts that you wish to share content with and/or invite to join Ci. From time to time we may also request additional demographic information which you may provide at your discretion.

Your Content. We collect and store files you upload, download or access with Ci, along with any metadata associated with that content or any metadata created in association with your use of Ci (e.g., user-entered tags and classifications, user comments).

Log Data. When you use Ci, we automatically record information from your device, its software, and your activity using Ci. This may include your IP address, browser type, access times, referring website addresses or other information included in HTTP headers. We may also collect information about your account activity and files and pages accessed by you. Such information is sometimes referred to as web analytics and/or clickstream data.

A “cookie” is a small file which is downloaded through your browser when you visit a website and stored on your device’s hard drive. We may use “persistent cookies” to save your login email and password for future logins to Ci. We may also use “session ID cookies” to enable certain features of Ci, to better understand how you use Ci, and to aggregate usage and web traffic routing on Ci. Most browsers automatically accept cookies as the default settings. You can instruct your browser, by changing its settings, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you do not accept cookies however, you may not be able to use or access all aspects of Ci.

To learn more about the use of cookies in online services, including how to manage or delete them click here.

We and some of our third party partners use Flash cookies to store some of your preferences or personal information. For more information on Flash cookies and how to manage privacy and storage settings click here. In some of our email messages, we use “click-through URLs” or pixel tags to determine whether the email has been opened and to measure the effectiveness of our customer communications.

2. How We Use Your Information. In general we use your personal information to process your requests or transactions, to provide you with information or services you request, to facilitate your use of Ci, to inform you about products, services or promotions we think may be of interest to you, and to otherwise serve you. In particular, we may use your personal information to:

  • Administer your account and provide you access to Ci;
  • Enable any premium services you have purchased, process transactions and send you billing invoices;
  • Respond to your customer service requests, questions and concerns;
  • Provide you with service notices and product announcements;
  • Send you requested updates and newsletters about Ci or other services;
  • Send you marketing, informational, product development and promotional communications;
  • Request feedback and enable us to develop, customize and improve Ci;
  • Conduct research and analysis about Ci;
  • Enable you to communicate, collaborate and share your content with other Ci users you designate;
  • Send emails to users you invite (and contacts you invite to join Ci) to collaborate and access your content.

3. Information Sharing. We will not give, sell, rent, share or trade any of your personal information or content that you store in Ci with any third party except as outlined in this Privacy Policy, or with your consent. To the extent we share your information with third party companies, these companies are authorized to use your personal information only as necessary to provide these services. For clarity, we do not currently share information with other third parties for their use in marketing activities.

We may also share your personal information:

  • With Sony MCS affiliates and representatives;
  • As required by law, such as to comply with a subpoena or similar legal process;
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request;
  • In connection with a corporate change including a merger, acquisition or sale of assets;
  • With collaborators you chose to share your content with.

Service Providers, Business Partners and Others. We may use certain trusted third party companies and individuals to help us with our business activities (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of Ci’s features). These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. As of the date this policy went into effect, we use Amazon’s S3 s storage service to store some of your information (for example, your content). You can find more information on Amazon’s data security from the S3 site.

Aggregate Data. Aggregate data is information we collect about a group or category of services or users for which individual user identities have been removed. No personal information is included in aggregate data. Aggregate data helps us understand trends in our user’s needs so that we can better consider new features or otherwise modify or improve our services. This Privacy Policy in no way restricts or limits our collection or use of aggregate data, and we may share aggregate data about our users with third parties for various purposes, including to help us better understand our customer needs and improve our services and for advertising and marketing purposes.

4. Network and Information Security. We seek to maintain reasonable security measures to help protect your personal information against unauthorized or accidental disclosure, access, misuse, loss, or alteration. Although we strive to protect your personal information, we cannot ensure or warrant the security of such information. There is no such thing as perfect security. In addition, we cannot guarantee that any passively-collected personal information you choose to include in the files you store in Ci are maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.

5. Updating and Accessing Your Personal Info. You may view, correct, update or delete the Personal Information Sony MCS stores about you. Most of your Personal Information may be accessed and corrected simply by logging into your account and accessing your profile. You can also request changes or access to your information by contacting us here.

6. Data Retention. We will retain your information for as long as your account is active or as necessary to provide you services. If you wish to cancel your account or request that we no longer use your information to provide your services, you may delete your account by contacting us here. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there may be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we may not delete files that you have in common with other users from our servers.

7.  Use of Analytics Tools. We may use analytics tools and other third party technologies such as Google Analytics and DoubleClick Cookies to collect non-personal information in the form of various usage and user metrics when you use Ci or visit our websites. These tools and technologies collect and analyze certain types of information including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information. These tools use this information for purposes such as monitoring product performance so that we may evaluate feature performance and overall product performance to improve the UX for our users.

To learn more about the privacy policy of Google Analytics, click here, and to learn how to opt-out of these services click here.

In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of Ci and to otherwise collect and use data about your use of Ci. We use Google AdWords Remarketing to advertise Ci across the Internet. Google AdWords Remarketing will display relevant ads tailored to you based on what parts of our website you have viewed by placing a cookie on your machine. This cookie does not in any way identify you or give access to your computer. The cookie is used to communicate that Google should show you ads related to pages you have visited. Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and display ads that are most relevant to you.

If you do not wish to participate in Google AdWords Remarketing, you can opt-out by clicking here, or learn more about opting out of third party cookies by clicking here.

8. Choice/Opt-Out. Sony MCS may send you communications regarding Ci, including but not limited to (i) notices about your use of Ci, including any notices concerning violations of use, (ii) service notices and product updates, and (iii) promotional information, newsletters and materials regarding our products and services. You may opt-out of receiving promotional emails by following the opt-out instructions in those emails or by setting your preferences in your account page or by contacting us here. Opt-out requests may not apply to certain types of transactional service messages.

9. Changes to this Policy. By using Ci, you agree to the terms of this Privacy Policy. We may amend this Privacy Policy at any time and, as such, we encourage you to periodically review this page for the latest information on our privacy practices. If we make a material change to the way in which we collect, use, and/or share your personal information, we will send an email to users who have provided an email address or post a notice on Ci prior to the change becoming effective. Your continued use of Ci after a revised version of this Privacy Policy has been posted will signify your consent to the terms of such revised policy.

10. Your California Privacy Rights. If you are a California resident, California Civil Code Section 1798.83 provides you the right to receive (a) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed.  To obtain such information free of charge, please write to us at the address below, or submit your request here. We will respond to these requests within thirty (30) days. Requests that come to us by other means may result in a delayed response.

11. Children. We do not attempt to collect any personal information from those under the age of 13. If you feel that we have unknowingly collected information from someone under the age of 13, please contact us immediately and this information will be removed. For more information on how to protect your children online:
Visit www.OnGuardOnline.gov for social networking safety tips for parents and youth.

12. International Users. Ci is operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States with laws governing data collection and use that may differ from U.S. law, please be aware that information we collect will be transferred to and processed in the United States. By using Ci, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

13. Questions About This Privacy Policy. If you have questions or concerns regarding this Privacy Policy, you should first contact Sony MCS. You can contact us about this Privacy Policy clicking here.