privacy policy (REVISED)

This Privacy Policy applies to the Sony Pictures Entertainment web sites and online features that link to this Privacy Policy (each a “Site”). The Sites are offered by SPE Networks - Asia Pte. Ltd., 10 Changi Business Park Central 2, #03-01 Hansapoint@CBP, Singapore 486030, and its subsidiaries or affiliated companies (collectively, “SPE,” or “we,” “us,” and “our”).

SUMMARY OF KEY POINTS

  • We use Personal Data to allow you to participate in the features on the Site, to process your registration, and to provide you with other requested content related to our movies and other offerings. Click here to learn more.
  • We provide interactive features that engage with third party social media sites, such as Facebook and Twitter. Any data that we obtain about your use of such features is subject to this Privacy Policy. Any data that the social media sites gather about you is subject to your terms with them. Click here to learn more.
  • We use cookies and other technologies to track the use of our Site. We allow third parties to place such technologies on our Site to allow them to display advertising and for other purposes. To learn about opportunities to choose not to allow cookies, click here.
  • If you are under 18 years old, you must obtain the permission of your parent or guardian before participating in a contest or engaging in other activities. The only exceptions are if you simply sign up for a newsletter or request certain basic content. Click here to learn more.
  • We disclose your Personal Data publicly when you post User-Generated Content on the Site. We also disclose Personal Data when you request or agree to such sharing with business partners or other third parties, when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Click here to learn more.
  • This Site may be hosted on web servers in the United States. Your use of the Site constitutes your consent to the transfer of Personal Data to the United States, a jurisdiction that may not provide the same level of data protection as your home country. Click here to learn more.

1. INFORMATION COVERED BY THIS PRIVACY POLICY

Information You Provide
We may collect personal data, including your name, email or street address, data of birth, telephone number, your preferences and interests, or other information you provide to us or grant us access to (“Personal Data”) when you register for newsletter, communicate with us, or take part in interactive games, features or competitions. We may also collect any photographs, video images or other user generated content that you may upload to the Site (“User-Generated Content” or “UGC”).

Automatic Information Collection
We may use a variety of technologies that automatically or passively collect information about how the Site is accessed and used (“Usage Information”). Usage Information may consist of your browser type, operating system, the page served, the time, and the preceding page views. Usage Information is generally non-identifying, but if we associate it with other information so that you can be identified, we treat it as Personal Data.

We also automatically collect your IP address or other unique identifier for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site. 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 (“Device Identifier”). Some mobile service providers may also provide us with the physical location of the Device used to access the Site.

Third Party Interactive Features
You may participate in a third party feature on our Site, such as through: a login to the Site using Facebook Connect; participation in a game or other feature where your score is posted on a social media site; or an interaction with a “like” or a “share” button for a feature on our Site. You may also engage in activities on third party sites, such as participation in a Facebook application where you allow us to have access to your Personal Data. In addition, we may receive Personal Data about you if other users of a third party web site give us access to their profiles and you are one of their “connections” or similar features. The Personal Data that we obtain through these activities is subject to this Privacy Policy. The information obtained by the third party is not subject to this Privacy Policy, and instead is governed by any terms applicable to your relationship with such third party.

Cookies and Other Tracking Technologies
By using the Site, you consent to our cookies. Cookies are files that web servers place on your Device. The use of cookies on the Site allows you to enjoy more seamless visits and more accurately measures your behavior on the Site. There are two types of cookies that we may use: session and persistent. Session cookies exist only during an online session. They disappear from your Device when you close the browser software. Persistent cookies remain on your Device after the browser has been closed. The cookies used on the Site do not identify you personally. They merely recognize your browser, unless you choose to identify yourself voluntarily. You may choose to identify yourself for any one of the following reasons: by asking the browser to remember your username and password, by responding to a promotional offer, or by personalizing a web page or requesting more information on a product or service.

Web beacons (also known as clear gifs) are used in combination with cookies to help Site operators understand how you interact with their websites. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email. The use of a clear gif allows the Site to measure your actions in opening the page that contains the clear gif.

How We Use Cookies and Web Beacons
SPE may use cookies and web beacons for a number of purposes, including to:

  • Provide general internal and customer analytics.
  • Study traffic patterns in order to improve website performance, to customize the user experience, and to better match the users’ interests and preferences. For example, SPE keeps track of the domains from which people visit, and also measures visitor activity on SPE websites. However, these tracking records are performed and maintained in ways that keep the data non-identifiable.
  • Keep track of preferences you specify while you are using SPE products or services.
  • Support security measures, such as requiring re-login into a SPE product or service after a certain amount of time has elapsed.
  • If you login to our products through the Site, cookies can also be used to save the username so that we can process the saved login information and quickly log you into the product.
  • Assist in identifying possible fraudulent activities.
  • Tell if an email has been opened and acted upon.

Controlling Our Use of Cookies

  • You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
  • If you do not wish to allow your session visit information on the Site to be aggregated and analyzed by us, you may utilize the following opt out mechanism. Click here to opt-out of use of session cookies for Site analysis purposes.
  • The Adobe Flash Player is an application and web tool that allows rapid development of dynamic content. Flash (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your web browser. SPE employs Adobe Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. You may access your Flash management tools from Adobe’s web site directly. Click here to manage the use of Adobe Flash applications. SPE does not use Flash cookies to serve interest-based advertising.
  • For further information about cookies you can visit www.allaboutcookies.org. If you choose to decline cookies, you may not be able to login or use other interactive features of our Sites and features that depend on cookies.

Third Party Cookies on SPE

For analytics services, we may use Omniture, a web analysis service provided by Adobe. To opt out of Omniture’s cookie tracking see www.omniture.com/en/privacy/product#optout

This Site may also use Google Analytics, a web analysis service of Google Inc. (“Google“). Google Analytics uses cookies, text files that are stored on your Device and allow an analysis of your use of the Site. If Google Analytics are used, the information generated by the cookie about your use of the Site (including the IP address) will be transferred to and stored on a server of Google in the US. Google will use such information, to analyze your use of the Site, to create reports about the web site activities for SPE and to provide further services associate with the use of the Site and the internet. Furthermore, Google may transfer such information to third parties, to the extent legally required or if such third parties process the data on behalf of Google. In no event will Google associate your IP address with other information of Google. You may prevent the installation of cookies through your browser settings; please note, however, that in this case not all functionalities of the Site may be available to you. By using this Site, you consent to the processing of your information collected by Google as described above and for the purposes described above.

Google Analytics can be disabled through this link: tools.google.com/dlpage/gaoptout

2. MINOR'S PERSONAL DATA

Certain Sites may attract individuals younger than 18 years old of age ("Minor" or "Minors"). On those Sites, SPE may collect the e-mail address and age of Minors in order to send them newsletters and engage in other limited activities. If you are a Minor, and you wish to provide us with your Personal Data for any other purposes, such as to participate in a promotion or contest, you must read this Privacy Policy with your parent or guardian and may not provide your Personal Data without obtaining first your parent’s or guardian’s prior consent. If we are notified or otherwise learn that a Minor has submitted Personal Data to us through any of our Sites other than under the conditions set forth above, we will delete that Minor's Personal Data. Children younger than 14 years of age may only surf the Site and play with features, but SPE does not knowingly collect data of users younger than 14 years of age.

3. HOW WE USE YOUR INFORMATION

We will use Personal Data collected through the Sites to: (1) allow you to participate in the features we offer on the Site; (2) process your registration and/or upload your UGC; (3) provide you with information that you request or agree to receive; (4) improve the Site and for internal business purposes; (5) contact you with regard to your use of the Site, and any changes to our policies; (6) tailor content, advertisements and offers we serve you; and (7) fulfill other purposes disclosed at the time you provide your Personal Data or otherwise with your consent.

4. HOW WE SHARE YOUR PERSONAL DATA

We may share Personal Data with the following parties:

When You Agree To Have Your Personal Information Shared
While on our Site, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your Personal Data with a third party. If you agree to have your Personal Data shared, your Personal Data will be disclosed to the third party and the Personal Data you disclose will be subject to the privacy policy and business practices of that third party. 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.

Personal Data That You Disclose Publicly on the Site
You may submit UGC to the Site. Any such UGC will be disclosed publicly. This Privacy Policy does not apply to third party uses of any UGC after it is displayed on the Site.

Third Parties Providing Services on Our Behalf
We may engage third parties to perform functions on our behalf, such as hosting or operating our Site, sending e-mail communications, and data analysis. We may share Personal Data with third parties in order for them to provide content or otherwise perform services for us, and we will require such parties to maintain appropriate security to protect such data from unauthorized access or processing.

Affiliate Sharing and Business Transfers
We may share your Personal Data with other entities affiliated with us for internal reasons, primarily for business and operational purposes. SPE or any of its assets, including the Site, may be sold, or other transactions may occur in which your Personal Data is one of the business assets of the transaction. In such case, your Personal Data may be transferred.

Legal Protections and Other Disclosures
We may transfer and disclose information, including your Personal Data, Usage Information and Device Identifier (including IP address), to third parties: to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce the Site's Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to this Site or the public. Pursuant to valid requests by law enforcement agencies, we may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.

5. LINKS TO OTHER WEB SITES AND SERVICES, AND SPE CONTENT FOUND ON OTHER WEB SITES

The Site may contain links that will direct you to other websites or services that are operated and controlled by third parties. This includes links from advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. We have no controlover these third parties, and your use of their websites and features are subject to their privacy policies. SPE is not responsible for the privacy practices or business practices of any third party web site. In addition, SPE may place our widgets or other features on certain third party web sites. When we do so, any Personal Data that we obtain about you will be subject to this Privacy Policy.

6. CONSENT TO TRANSFER

The Site is hosted and operated in the United States. Your Personal Data will therefore be transferred to and processed in the United States where the privacy laws may not provide an equivalent level of protection to those in your home country. By using the Site, and providing us with any information, you consent to the transfer of your information to, and its processing in, the United States.

7. AMENDING OR REMOVING YOUR PERSONAL DATA

You have the right to access your Personal Data held by us and, if necessary, have it amended or deleted. You can also request not to receive email communications and/or other marketing information from us. For more details please contact us by email at SonyPrivacy@spe.sony.com or write to us at:

Data Protection Officer
SPE Networks - Asia Pte. Ltd.
10 Changi Business Park Central 2
#03-01 Hansapoint@CBP, Singapore 486030

8. NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY; PRIVACY QUESTIONS

Except to the extent limited by applicable law, we reserve the right to change the terms of this Privacy Policy at any time, by prominently posting notice of the amendment on this Site. The changes will become effective fourteen days after posting and will apply to any Personal Data you provide to us after that date. If we make any changes to this Privacy Policy that materially impact the way that we collect, process or store your Personal Data, we will, to the extent that we have your email address, notify you by email. You will be given the choice at that time to consent to the use of your Personal Data in such manner.


Effective Date: This Privacy Policy was updated July 2, 2014 and is effective as of that date.

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