PRIVACY AND COOKIES POLICY

For more information on each of these key points, see the full wording of the Policy below.

We may collect the following categories of Personal Data you provide to us when using the Content:

• Identification Data: Information that allows us to differentiate you from other individuals. This may include demographic information, such as: name and surname, date of birth, gender, postal address, username, password, and answers to account security questions.
• Contact Information: Information that allows us to keep in touch with you. This may include: email address and phone number.
• Payment Information: information that allows us or our third party providers to process payments where required to grant you access to our Content, related purchase or subscription status, and payment history.
• Your Entries or Comments:  Information you provide when participating in one of our competitions, prize draws, or one of our surveys or consumer research.
• Your Enquiries: Information you provide when you contact us seeking customer support.
• User-Generated Content: When we provide you the opportunity to upload or share user-generated content, we will collect information that you provide to us through our Content, such as photographs, video images or other content that you may upload.
• 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, videos and apps you viewed, the time you viewed them and for how long, game or video history, skill level, demographic information about you (such as your age, gender, language, location and interest areas, where available), time zone, language, and what you looked at before accessing our Content. For more information about the collection of some of this information, please also see the section on Cookies and Similar Tracking Technology.
• 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 service providers may also provide us with the physical location of the device used to access the Content. For more information about the collection of some of this information, please also see the section on Cookies and Similar Tracking Technology.

Our sites and applications may contain links to other sites not owned or controlled by us. When you leave our site or platform your information may be collected by a third party and subject to their privacy and cookie notice.

The Content may include hyperlinks in association with the Content, plug-ins, websites, locations, platforms, applications, or other 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.  Third-Party Services may in certain circumstances provide SPE certain Personal Data, such as identification data, demographic information, contact information, your comments and user generated content, usage information, inferences about you, and device identifiers.  To the extent relevant under applicable law, where we control your Personal Data jointly with third parties, we will provide you with information about this relationship at the point of collection or through the Cookie Consent Tool.

We use the categories of Personal Data outlined above for the following purposes and, where we are required to have a legal basis, we rely on the following legal bases:

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 your interactions with the Content or the emails which SPE sends to you, including information about your browsing and purchasing behavior.

We use tracking technologies for three purposes:

• To provide you with the service(s) and setting(s) you have requested: for example, letting you navigate between pages efficiently, keeping you logged in during your visit, checking for bugs and glitches in the Content, to comply with applicable law, and ensuring security of the Content. We typically collect account information such as username and password, device identifiers, usage information as it relates to glitches, bugs, or Content security issues, and the preferences you select for these purposes.

• To show adverts and Content recommendations that are more relevant to your interests: for example, we use tracking technologies to remember Content that has interested you, to make Content recommendations and tailor Content, 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 typically collect contact information, device identifiers such as IP address, and usage information such as your ad interactions, browsing history, and viewing history for this purpose.

  We also allow other organizations to use tracking technologies for these advertising purposes. In addition, we 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 can find information about these third-party platforms and websites in our Cookie Consent Tool.  

  To the extent required by law, we will ask for your consent before setting these cookies. To learn more about certain cookies used for interest based advertising as described above 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.

• To analyse and improve your browsing experience: to analyse 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 remember the choices you have made, such as your language or region, to enhance and personalize your experience.  We may also remember the place where you have left off viewing the Content, so that you can return to the same place when you view the Content again.  We typically collect device identifiers such as IP address and usage information such as browsing history, device and browser type, and operating system for this purpose.  We use analytics services provided by Adobe, Google, and others to help us analyse and improve your browsing experience as outlined in this paragraph; you can find their cookies policies at the following links here for Adobe and here for Google. To the extent required by law, we will ask for your consent before setting these cookies. If you change your mind or 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 follow the instructions below for other analytics services.  

How to manage tracking technologies

We keep information collected from cookies for no longer than the maximum period permitted by law.

To the extent required by law, we will ask for your consent and provide a link to this Policy before setting any non-essential cookies (i.e. the cookies in categories (2) and (3) above) and before using pixel tags in emails sent to you (which we ask for at the same time as your direct marketing preferences). You are able to withdraw this consent at any time using the methods described below or as otherwise specified in the Content. 

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 Cookie Consent Tool. 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, 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.

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

When you access certain applications from these devices, cookies, and other tracking technologies will be automatically stored to your device for the following purposes: keeping you logged in, managing parental control PINs, financial reporting, and for other purposes permitted by applicable law. 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.

We may share your Personal Data in the following circumstances:

• With your consent (including for Marketing and Promotions). We may ask for your consent to share your Personal Data with third parties for their own marketing purposes, and if you give your consent, we will share it in accordance with applicable law.  For example, we may share your Personal Data with marketing and promotional partners, social media platforms, and business partners.  We give you the name of the third parties that we share your Personal Data with at the time of obtaining your consent.  At times, through your use of an interactive feature, a widget or an application, you may ask that we share your Personal Data with a third party and we will do so under those circumstances in accordance with applicable law.  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 and in accordance with the terms 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.
• 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, performing marketing and advertising services, 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.
• 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, account authentication, account management, 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.
• 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.
• 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.

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. For a list of countries where your Personal Data may be transferred please see here. We provide appropriate protections for international transfers as required by law for international data transfers. With respect to transfers originating from a country or a region such as the United Kingdom or the European Economic Area ("EEA"), and if the transfer is not to a country which is the subject of an adequacy decision or adequacy regulation (or equivalent), we implement appropriate solutions to address cross-border transfers as required by applicable law such as, with relation to the EEA, standard contractual clauses approved by the European Commission; and with the UK, standard contractual clauses approved by the UK government. Under such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed here.  Where your consent is required by applicable law for the international transfer of Personal Data, by using the Content and providing us with your Personal Data, you consent to the international transfer of your Personal Data.

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 to object to, 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 reasonable 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 change, remove or delete your information or public postings from our databases and residual and/or cached data may remain archived thereafter if our retention of this data falls within an exemption from the fulfilment of your data subject rights under applicable law.  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.

We maintain appropriate technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction.  We protect your information in accordance with standards required by applicable law, though note that as technologies change we cannot guarantee that all of our security measures will be perfect or impenetrable.  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.

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.

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.

For Personal Data that we collect and process for the purposes described above, we retain such Personal Data for no longer than the period necessary to fulfil the purposes outlined in this Privacy and Cookies Policy. This may include retaining Personal Data for longer than the period for which we provide you with our services in order to address tax, corporate, compliance, litigation, and other legal rights and obligations. We retain Personal Data related to marketing activities for the time period permitted by applicable law (unless you withdraw your consent at an earlier stage), and upon request we will securely delete such data in accordance with applicable law.

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 when legally required by applicable law.

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.

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