Privacy Policy for C3 Portal

IMPORTANT NOTICE–PLEASE READ CAREFULLY. THIS PRIVACY POLICY EXPLAINS i) HOW SONY CORPORATION ("SONY", "WE", "OUR" OR "US") MAY READ, COLLECT, USE AND/OR STORE INFORMATION ABOUT YOUR USE OF THE C3 Portal (“C3 Portal Service”); ii) SONY’S POLICIES FOR THE COLLECTION USE AND DISCLOSURE OF YOUR INFORMATION IN CONNECTION WITH YOUR USE OF THE C3 Portal SERVICE AND WEBSITE, AND iii) HOW YOU CAN CONTACT US. WE ENCOURAGE YOU TO REVIEW THE ENTIRE PRIVACY POLICY.

Sony values your privacy and believes you have the right to know what type of information we may collect when you interact with or use our products, and our practices with respect to that information. This privacy policy (the “Privacy Policy”) governs your access to the C3 Portal Service and any related websites, applications and software, all of which are marketed as C3 Portal. Please read this Privacy Policy carefully and indicate whether you agree to its terms by selecting the button or checkbox describing your consent or refusal. If you sign-in to an account on behalf of any legal entity (including cases where you create corporate accounts for other officers and/or employees of your company), you affirm that you are authorized to provide the information on behalf of such legal entity, other officers and/or employees, and accept this Privacy Policy by such legal entity and such other officers and/or employees. Our Privacy Policy is intended to assist you in making informed decisions when using our services, and in particular the C3 Portal Service. This Privacy Policy is in addition to any other privacy policy that may apply to your interactions with any Sony affiliate, subsidiary, product, software or service including but not limited to the Professional Solutions Latin America privacy policy located at https://pro.sony/ls_BO/home

Sony is acting as a data controller with respect to your personal information listed in Section 3 below other than “Your Content”, with respect to which Sony may be acting as a data processor.

To help protect you and others, we monitor the use of the C3 Portal, 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, 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 C3 Portal immediately.

1. Summary of Key Points

‧ We use the Collected Data (defined below) to provide you with features and functions of the Application, and to provide you with other requested content related to our services and other offerings. We also use the Collected Data to improve and develop SONY Group’s current and future products and services. Please read here to learn more.

‧ This Privacy Policy also describes your data protection rights, including a right to object to some of the processing which SONY carries out. Please read here to learn more about your rights.

‧ We disclose the Collected Data when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Please read here to learn more.

‧ Depending on where you are located, the Collected Data may be transferred out of your home country/region to the United States of America, Japan and other jurisdictions that may not provide the same level of data protection as your home country/region. Please read here to learn more.

2. Which service is covered by this policy?

Sony may collect and consolidate various information about you and your interactions with the following service when you use it: C3 Portal.

About the C3 Portal Service

The C3 Portal Service is a cloud service provided by Sony or Sony’s affiliates that expands the capabilities of news production workflows. The C3 Portal Service enables you to stream and edit video  sent from XDCAM camera products which are registered on the C3 Portal Service ("XDCAM Products”).

3. What information is obtained about you by the C3 Portal Service?

In addition to information you provide when you sign up for an C3 Portal Account, Sony may collect the following information about you (the “Collected Data”) when you use the C3 Portal Service:

C3 Portal Account information

(a) Sony’s Account Identifier. In order to use the C3 Portal Service, you need to sign-in using your or your company’s Professional ID account, which you or your company create in accordance the terms and conditions separately provided by Sony or Sony’s affiliates on the Professional ID Service Website. When you sign in to your C3 Portal Account, you provide your Professional ID and password to us.

(b) Information relating to your C3 Portal Account. In order to use certain functions of the C3 Portal Service via XDCAM Products, you may need to sign-in to your or your company’s C3 Portal account, which you or your company create in accordance the terms and conditions separately provided by Sony or Sony’s affiliates on the C3 Portal Service and which is used to connect the C3 Portal Service to Sony devices owned and registered by you or your company on the C3 Portal Service ("C3 Portal Account”). When you have successfully signed-in to your C3 Portal Account via XDCAM Products, Sony may combine information collected automatically with information that you or your company provided during the C3 Portal Account registration process.

(c) Your Content. We collect and store files you upload, download of?? or access with the C3 Portal Service, along with any metadata associated with that content or any metadata created in association with your use of the C3 Portal Service (e.g., user-entered tags and classifications, user comments, etc).

(d) Log Data. When you use the C3 Portal Service, Sony may automatically record information from your device, its software, and your activity using the C3 Portal Service. 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 C3 Portal Account activity and files and pages accessed by you. Such information is sometimes referred to as web analytics and/or clickstream data.

Third Party Network Service Information

(a) Third Party Network Service Account 'tokens'. In order to use certain functions of the C3 Portal Service, you may need to sign-in to certain third party network service account that we designate ("Network Service Account"). You provide your Network Service Account ID and password directly to such Network Service Account provider, which controls this sign-in process independently of us. Once you have successfully signed into your Network Service Account, C3 Portal Service will receive a digital 'access token' from such Network Service Account. This token will be used to connect such Network Service Account and Professional ID.

(b) Information relating to your Network Service Account. When you have successfully signed-in to your Network Service Account via C3 Portal Service, Sony may also receive your account ID of such Network Service Account.

Information Collected Automatically

Sony may also receive certain information automatically when you use the C3 Portal Service:

• Network service provider for the XDCAM Products
• Electric field intensity of your XDCAM Products and wireless LAN network
• Product model and version of the XDCAM Products
• Usage log of the XDCAM Products
• Usage log for mobile application dedicated to the C3 Portal, such as XDCAM Pocket
• Geolocation information of XDCAM Products

Information collected automatically described above is used for managing your XDCAM Products on the C3 Portal Service.

If you wish to stop automatic data collection, you should disconnect XDCAM Products’ network connection or cease using device connectivity function of the C3 Portal Service.

If you or your company use Google Maps on the C3 Portal Service, you shall follow the Google Maps/Google Earth Additional Terms of Service including the Google Privacy Policy.

4. How does Sony use your information?

In general we use your personal information as required to establish and fulfill a contract with you (if you act as an individual), for example to process your requests or transactions, to provide you with information or services you request, to facilitate your use of the C3 Portal Service, and to otherwise serve you. In particular, we may use your personal information to:

• Administer your account and provide you access to the C3 Portal Service;
• Enable any premium services you have purchased, process transactions and send you billing invoices;
• Respond to your customer service requests, questions and concerns;
• Enable you to communicate, collaborate and share your content with other C3 Portal Service users you designate.
• Send emails to users you invite (and contacts you invite to join C3 Portal) to collaborate and access your content.

We may also use your personal information as required by to enable our business and pursue our legitimate interests, in particular to:

• Provide services to users authorized to use our services by an entity, with whom Sony has a contractual relationship;
• Send you marketing, informational, product development and promotional communications;
• Request feedback and enable us to develop, customize and improve the C3 Portal Service;
• Conduct research and analysis about the C3 Portal Service;
• To improve our products and services and to develop new ones;
• Provide you with service notices and product announcements;
• Send you requested updates and newsletters about C3 Portal Service or other services;
• Monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
• monitor use of our websites and online services, and may use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;

Moreover, we may process your personal data as required for compliance with applicable laws and protection of Sony's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation). Sony may collect and/or analyze the information collected in accordance with this Policy in order to identify potential security threats and to protect Sony, its users and its affiliates. To help protect you and others, we monitor use of the C3 Portal Service, 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, its partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through our website.

In addition, with your consent (if required under applicable law), we may send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. Although these will only be sent where you have given your consent, or (where permissible) you have been given an opportunity to opt out, you will be able to opt-out of electronic direct marketing by following the instructions in the communication.

5. Who else has access to your information?

Sony will not give, sell, rent, share or trade any of your personal information or content that you store using the C3 Portal Service 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. Your information that is communicated to and stored by Sony may be made available to other Sony group companies and to third parties, as follows:

• With Sony group companies, affiliates and representatives for the purposes of the activities outlined in Sections 3 and 4 above;
• As required by law, such as to comply with a subpoena or similar legal process with government authorities and/or law enforcement officials;
• 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 with whom you chose to share your content.

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 C3 Portal’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 and, for the purposes listed above. 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.

6. Updating and Accessing Your Information.

You may be entitled to ask Sony for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations. You may also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

We hope that we can satisfy all queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at SOLAPrivacy@sony.com.

7. Data Retention, Managing Your Information

We will retain the Collected Data for as long as your account is active or as necessary to provide you services, and for one (1) year after you unsubscribe C3 Portal. If you'd like us to delete user provided data that you have provided via the C3 Portal Service, please contact our Personal Information Management Office at this email: SOLAPrivacy@sony.com and we will respond in a reasonable time and manner. We may retain and use your information as necessary to perform the purposes set out in this notice, as well as to comply with our legal obligations, resolve disputes, and enforce our agreements. Moreover, laws may require Sony to hold certain information for specific periods. 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.

8. Transfer of Your Information Internationally

Your information will be processed, stored and transferred for the purposes outlined in Sections 3 and 4 to various countries outside the European Economic Area (EEA) and/or your country of residence, including Japan and the United States. Your information 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. In particular, you are hereby informed and consent that your information may be transferred to Sony Latin America Inc. established in the United States, which is a country that is not regarded as providing an adequate level of protection, and you are informed that Sony has implemented appropriate safeguards to ensure these data transfers are made in compliance with applicable local laws.

9. Network and Information Security

Sony undertakes reasonable security measures designed to protect against the loss, misuse or alteration of your information. Although we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to us through the C3 Portal Service or that we store on our systems or that is stored on our third party contractors' systems. 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 the C3 Portal Service are maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.

10. Choice/Opt-Out.

In accordance with local laws, Sony may send you communications regarding the C3 Portal Service, including but not limited to (i) notices about your use of the C3 Portal Service, 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.

11. 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. 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 below.

12. Privacy Rights (including California Privacy Rights)

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 the right to request a copy of the personal information that we hold about you and/or you may request that we correct, amend, delete or block such personal information if it is inaccurate. If you would like to exercise any of these rights, please contact our Personal Information Management Office at this email: SOLAPrivacy@sony.com

13. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy. You are advised to consult the posted Privacy Policy regularly for any changes.

14. Contact Information

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have in respect of your personal information, please contact our Personal Information Management Office at this email: SOLAPrivacy@sony.com

Last Update: 26 Nov 2021