Updated and Effective March 2023:  This privacy policy (“Privacy Policy”) applies to the information collected by Crispin Corporation, a Sony Group company, (“Crispin”, “our”, “us” or “we”), both offline and online, including through  https://www.crispincorp.com and related websites that accurately post a link to this Privacy Policy, or through any products, applications, services, interactive features, blogs, social networks or other offerings, whether accessed via computer, mobile device or other technology (collectively “Properties”). Please note that when you enter any subsites accessible through https://www.crispincorp.com, including any websites of affiliated Sony Group companies, such subsites may have their own specific privacy policies; therefore, please review the privacy policy notices on those websites if you visit them. This Privacy Policy explains the information that Crispin may collect when you interact with us and our practices with respect to that information. Please read this Privacy Policy carefully. If you do not consent to this Privacy Policy and the Terms, you must discontinue your use of the Crispin Properties.

The Properties are not intended for use by anyone younger than the age of 18. Accordingly, we do not knowingly collect personal information from users younger than the age of 18.

Crispin, a company having its registered address at 600 Wade Avenue, Raleigh, NC 27605, is the data controller. Crispin is responsible for and controls the processing of personal information on the Properties. This Privacy Policy applies only to instances where Crispin acts as a data controller. For additional information regarding our practices as a data controller, please refer to Notice to EEA/UK Residents below.

Table of Contents

1. Collection of Information
2. Uses of the Personal Information Crispin Collects
3. When and With Whom Crispin May Share Information Collected
4. Analytics and Similar Third Party Properties and Your Choices
5. “Do Not Track” & Global Privacy Control Signals
6. Links To and Crispin Content On Other Websites
7. Your Choices
8. Security
9. Consent to Processing
10. How Long We Hold Data
11. Changes to Privacy Policy
12. How to Contact Us
13. Notice to California Residents
14. Further Infomation for Individuals in the EEA, UK, and Switzerland

1. Collection of Information

1.1 Information You Provide To Crispin

In General

We collect information from you directly when you visit the Properties. We may also collect information automatically, such as your IP address. Some of this information may be considered “personal information” or “personal data” under various applicable laws. While Crispin does not generally require that you provide us with personal information in order to visit our website, please note that in order to participate in some activities, such as signing up for an account receiving newsletter communications, and using or purchasing our products, we may ask you to provide information that identifies you as an individual (such as first and last name, e-mail address, mailing address and telephone number).  We may also ask you to provide other information about yourself, including demographic information (such as geographic region, business, etc.) or certain information about your preferences and interests. If you choose not to provide such personal information or other information to us, you may not be able to participate in certain activities we offer.

If we combine demographic or other information we collect about you with personal information about you, we will treat the combined information as personal information.   We may also de-identify or pseudonymize personal information, turning it into non-identifiable information. This is sometimes accomplished using a mathematical process (commonly known as a “hash” function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law.

Information You Provide Us About Others.

While using the Properties, you may provide us with personal information of another individual, such as contact information. If you disclose any personal information relating to other people, you represent you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

1.2 Information Crispin Collects Automatically

In addition to any personal information or other information that you choose to provide to us, Crispin and its third parties may automatically collects certain information such as your IP address and/or other unique identifiers (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access or use the Properties and any referring website. (A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers. Our computers identify your Device by its Device Identifier.) Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Properties.

In addition, Crispin, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the Properties (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if Crispin associates it with you as a specific and identifiable person, we will treat it as personal information.

1.3 Cookies and Other Tracking Technologies.

The technologies used on the Properties to collect Usage Information, including Device Identifiers, may include the technologies described below. You may be able to disable cookies and similar technologies by adjusting your browser settings to disconnect the link between cookie information and non-personal viewing information generated by those technologies.

The methods used to collect Usage Information may include the following:

Cookies & Local Storage. “Cookies” (which may be html files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit our website or otherwise access our online content. Certain web browsers and certain browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our website may make use of this local storage. Cookies and other local storage devices may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your experience. Most browsers permit you to instruct your browser, by changing its settings, to refuse or remove some or all of these cookie and local storage technologies. For more information about cookies and managing cookies generally, visit http://www.allaboutcookies.org.

Web Beacons. “Web beacons” (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Properties, to monitor how users navigate the Properties, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.

Embedded Scripts. An “embedded script” is programming code that is designed to collect information about your interactions with our website, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Properties, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

1.4 Updating and Accessing Your Personal Information

You are responsible for maintaining the accuracy of the information you submit to us. You can request changes or access to your information by contacting us. Note that when you modify your personal information or change your preferences, information that you remove may persist internally for our administrative purposes or within backup media. Certain states provide additional rights. Please see our section for residents of California below for additional rights you may have.

2. Uses of the Personal Information Crispin Collects

Crispin will use the information it collects, including your personal information:

• to tailor your experience on the Properties;
• to determine which products and services we offer may be of interest to you;
• to allow you to participate in the Properties and features offered through the Properties;
• to process your registration with the Properties, including verifying that your email address is active and valid;
• to allow you to participate in the public areas and other features of our websites;
• to tailor content, recommendations, and offers we display to you, both on the Properties and elsewhere online;
• to provide you with you with customer service, support and answer questions or other requests;
• for other purposes disclosed to you at the time you provide your information; and

We may also use and share non-personal information in our discretion, and we may use non-personal information, including information that has been de-identified or pseudonymized to improve the Properties. In addition,  we may send you special offers from us, our advertisers, or third-party business partners. You will be able to opt-out of those materials by following the instructions in the communication.

We may also use the information we collect to improve the Properties and our products, for internal business purposes, to comply with regulatory and legal obligations, to contact you with regard to your use of our website, the Properties and, in our discretion, changes to any of our policies, and as further described in this Privacy Policy.

3. When and With Whom Crispin May Share Information Collected

3.1  Non-Identifiable Information.

To the fullest extent allowed by law, we may share non-personal information, such as aggregate user statistics, demographic information, de-identified information, pseudonymized information and Usage Information with third parties in our discretion.

3.2   Personal Information.

We may share your personal information as specifically disclosed at the time you provide your personal information, or otherwise with your consent, and as described below or elsewhere in this Privacy Policy.  California residents, please see below for additional information in the Notice to California Residents.

To Other Sony Group companies.
Crispin may share your personal information with other Sony Group companies (“Affiliates”), so that those Affiliates can (i) assist us with fulfilling your requests or improving our products, content, Properties or advertising; and/or (ii) contact you about products, content, Properties or other offerings that may be of interest to you. For purposes of this Privacy Policy, “Affiliates” means Sony Corporation, any company with respect to which Sony Corporation owns, directly or indirectly, 50% or more of its outstanding shares, and any company with the name “SONY” as a part of its trade name.

To Third-Party Service Providers Providing Properties On Crispin’s Behalf.

We may employ third parties to perform functions on our behalf, and thus, we may also share your personal information with third party service providers that assist us with data storage, providing content, fulfilling your requests, improving our products, content, Properties or advertising, or otherwise performing Properties for Crispin. As one example, if you access content or Properties that are published, developed or supported by an Affiliate or third party, your personal information may be shared with that Affiliate or third party for purposes related to that content or those Properties, including service administration and/or development. Additionally, we may share your information in order to host or operate the Properties and for data analysis purposes. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar vendors, and they will use this information to help us, and their other clients prevent fraudulent and illegal transactions.

Business Transfers.

We may share personal information with Affiliates for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. In addition, Crispin or any of its assets, including the Properties, may be sold, or other transactions or transitions may occur whether voluntary or involuntary (such as through bankruptcy) in which your information, including your personal information, is one of the key business assets in the transaction. In such a case, your personal information may be one of the business assets we transfer. By providing your information, you understand and agree that we may transfer such information in connection with any activity and/or transaction described above. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent, except where otherwise required by law.

Legal Protections and Law Enforcement.

We may transfer and disclose information, including your personal information, (including Usage Information and Device Identifier (including IP address)), to third parties: (i) to comply with legal obligations, such as respond to subpoenas or other legal processes; (ii) when we believe in good faith that the law requires disclosure; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our terms of service or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the Properties or the public. 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.

4. Analytics and Similar Third Party Properties and Your Choices

We may use analytics tools and other third-party technologies such as Google Analytics to collect non-personal information, including information that has been de-identified or pseudonymized when you use the Properties.

We may utilize third party analytics services in order to collect and analyze access logs or to aggregate date on our website visitors/behavior by using cookies. Examples of the type of information collected include, pages visited, interaction on pages, device and browser type, 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, the geographic location, 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 by downloading the browser add-on here.

5. “Do Not Track” & Global Privacy Control Signals

Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. When you choose to turn on the “Do Not Track” setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing, to stop tracking your activity.   To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.

Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more and to set up GPC, please visit https://globalprivacycontrol.org/#about.

6. Links To and Crispin Content On Other Websites

The Properties may contain links to other websites that are operated and controlled by third parties that we do not control. This includes links of advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. In addition, the Properties or other Crispin content may be included on web pages and other online Properties that are not associated with us and over which we have no control and which may send their own cookies to your Device and independently collect data or solicit personal information. A link from any service to any other online content does not mean that Crispin approves of, endorses, or recommends it. Crispin is not responsible for the privacy practices of any third party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content it does not own and control. Information collected by third parties is governed by its respective privacy policy.

7. Your Choices

We may send you communications regarding the Properties, including but not limited to (i) product updates, (iii) promotional information, newsletters and materials regarding our and/or our Affiliate’s and third- party’s 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.

8. Security

Crispin uses commercially reasonable safeguards to help protect and secure your personal information, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of personal information we share with them. However, no electronic data transmission or electronic storage of information can be guaranteed to be 100% secure.  Crispin does not ensure or warrant the security of any information we collect, and you use the Properties and provide us with your information at your own risk.

To help protect you and others, we monitor use of the Crispin Properties, and we use the information we collect, including personal information, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Properties; ensure compliance with this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of Crispin, its partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through the Properties. If you do not consent to these conditions, you must discontinue your use of the Properties. In addition, we cannot guarantee the security of any personal information you are the controller of.

9. Consent to Processing

The Properties are operated in the United States and the information we collect is governed by United States law. By providing any Personal Information to Crispin, all persons fully understand and unambiguously consent to the collection and processing of such information in the United States of America, and/or in territories or countries outside of the United States of America, 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. Personal information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.

10. How Long We Hold Data

We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations;  comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Properties or continuing to interact with us.

11. Changes to Privacy Policy

The terms of this Privacy Policy will govern the use of any information collected while it is in place. To the fullest extent allowed by applicable law, Crispin reserves the right to change this Privacy Policy at any time and will notify you of material changes by posting the revised Privacy Policy on our Properties. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will become effective immediately upon posting unless otherwise specified. We will not use your Personal Information in a manner materially different from the Privacy Policy in effect at the time we collected your Personal Information without your consent, but your continued use of the Properties after posting of any changes to this Privacy Policy will constitute acceptance of, and agreement to be bound by, those changes.  Note that you may need to consent to the new or revised policy in order to continue to access or use the Properties.

12. How to Contact Us

If you have any questions or comments about our practices regarding personal information or about this Privacy Policy, please email us at: privacy@am.sony.com, or you may call or write to us at:

Personal Information Management Office

Sony Electronics Inc.
115 W. Century Rd., Suite 250
Paramus, NJ 07652

(201) 930-4800

13. Notice to California Residents

This California Privacy Notice is effective as of January 1, 2023.

If you reside in California, and are a person with whom we have a direct business or potential business relationship with, this notice applies to you. We are required to provide additional information to you about how we collect, use and disclose your information, and the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (“CPRA”) provides you with  additional privacy rights . We have included this California-specific information below. This notice supplements the Privacy Policy. This California Privacy Notice sets forth the disclosures and rights for California residents regarding their Personal Information, as required by the CPRA. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.

California Rights. Subject to certain exceptions, as a California resident, you may have the following rights to your CA Personal Information:

• (i) Request to Know. Request access to the Personal Information that we have collected, used, disclosed, or sold about you, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you;
• (ii) Request to Delete. Request deletion of your Personal Information; provided that we may be required to retain some of your Personal Information and certain Personal Information is strictly necessary for us to fulfill the purposes described in this Privacy Policy;
• (iii) Request to Correct. Request that we correct inaccurate Personal Information we hold about you;
• (iv) Do Not Sell or Share (for Cross-Context Behavioral Advertising). Request to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising). As we do not knowingly collect Personal Information of residents younger than the age of 18, we also do not knowingly sell or share for cross-contextual behavioral advertising their Personal Information.
• (v) Right to Limit the Use and Disclosures of Sensitive Personal Information. Request that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, all subject to the meanings and exceptions set forth in the CPRA. We do not collect Sensitive Personal Information. If at any time this changes and we begin to use Sensitive Personal Information in a manner that triggers the opt-out right, we will update this notice accordingly. We, therefore, do not offer such this right at this time.

More information on these rights can be found below.

Exercising Your Rights. If you are a California resident with whom we have a direct business or potential relationship with and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please: (a) contact us by sending an email to privacy@am.sony.com with the specific nature of your request, referencing “California Privacy Rights – Crispin”; (b) submit a request using the webform here [https://privacyportal.onetrust.com/webform/ae4501a4-318f-4210-bddc-9a8bc984c5a6/e006e4a8-bd41-4340-b9d9-863c15a2532e]; or (c) call the following toll-free number 1-833-681-9900.

Do Not Sell or Share.

Right to Opt-Out of Sharing of Cross Context Behavioral Advertising:

California residents have the right to opt-out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. If you are a California resident with whom we have a direct business or potential business relationship and would like exercise your Right to Opt-Out of Sharing, please submit your request at https://privacyportal.onetrust.com/webform/ae4501a4-318f-4210-bddc-9a8bc984c5a6/e006e4a8-bd41-4340-b9d9-863c15a2532e

We engage in online advertising practices (and certain analytics or similar activities), which may be considered a “share” for cross-context behavioral advertising as defined in the CPRA. In addition to submitting the form above, you may need to disable sharing through cookies set by 3rd parties on certain websites. To manage your cookie preferences, please refer to the “Manage Cookies” link in the cookie banner or the footer for the applicable website and ensure that “Targeting Cookies” are disabled.

In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CPRA to opt out of the sale of personal information by some or all of the participating companies: https://www.privacyrights.info/.

Right to Opt-out of Sale

California residents have the right to opt-out of the sale of your Personal Information. We do not sell the Personal Information of consumers, and therefore, we do not offer an opt-out at this time.

We do not knowingly share or sell Personal Information of users younger than 18 years of age.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your  Personal Information.

Verifying Your Request.

When submitting your request, you must submit enough information to allow us to verify you are the person about whom we collected Personal Information or are their authorized representative.  When you exercise your Right to Know, Right to Delete, and/or Right to Correct, you may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that we cannot respond to your request if we can’t verify your identity. We will only use the information you provide to verify your identity. In order to have us provide specific pieces of information under the Right to Know, we may require a signed declaration under penalty of perjury that you are the California resident whose Personal Information is the subject of the request. Please note that as part of the verification process, once you submit a Request to Delete, we may follow up and require you to confirm that you want your information deleted.

Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sharing.

Authorized Agents: If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under California Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The California resident’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request.  We may also ask the California resident to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the California resident’s behalf, we may deny the request.

Data Retention. We retain all categories of Personal Information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the goods or services you request; exercise the choices and rights you have requested; comply with our contractual obligations;  comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Except as noted differently specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Properties or continuing to interact with us.

Personal Information We Collect. The Personal Information we collect about you will depend on how you interact with us. Accordingly, we may not collect all of the below information about you. Consistent with this Privacy Policy, we may collect the following categories of information about California residents (“Personal Information”) for the purposes described in this Privacy Policy, specifically:

Category of Personal Information Collected	Categories of Sources from which the Information was Collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose	Categories of Third Parties to Whom this Type of Personal Information is Sold/Shared for Cross-Context Behavioral Advertising
Identifiers (such as name, email address, contact information, IP address)	We may collect this type of information from: • You • Your Company • Affiliated and Sister Companies • Cookies and Tracking Technologies • Colleagues • Third party social media companies • Third party business partners and data providers	We may use this type of information to: tailor your experience on the Properties; to determine which products and services we offer may be of interest to you; to manage and develop our business relationship with you and the company for which you work; to allow you to participate in the Properties and features offered through the Properties; to process your registration with the Properties, including verifying that your personal information is active and valid; to tailor content, recommendations, and offers we display to you, both on the Properties and elsewhere online; to provide you with you with customer service, support and answer questions or other requests; operate and protect the Properties from errors and misuse, investigating and preventing fraud, illegal activities, and activities that violate our policies, and resolving technical issues; and for other purposes disclosed to you at the time you provide your information, or otherwise with your consent.	We may disclose this type of information to: • Subsidiaries, Affiliates and Sister Companies • Your Company • Service Providers • Third parties or affiliated companies when you agree to or direct that we share your information with them • Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition • Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) • Third party analytics companies	Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Any categories of Personal Information described in subdivision (e) of Section 1798.80 (such as name, signature, employer, address, phone number, job title, and categories of information classified as “personal” under this California law) Note: information in this category may overlap with other categories.	We may collect this type of information from: • You • Your Company • Affiliated and Sister Companies • Cookies and Tracking Technologies, • Colleagues • Third party social media companies, • Third party business partners and data providers	We may use this type of information to: tailor your experience on the Properties; to determine which products and services we offer may be of interest to you; to manage and develop our business relationship with you and the company for which you work; to allow you to participate in the Properties and features offered through the Properties; to process your registration with the Properties, including verifying that your personal information is active and valid; to tailor content, recommendations, and offers we display to you, both on the Properties and elsewhere online; to provide you with you with customer service, support and answer questions or other requests; operate and protect the Properties from errors and misuse, investigating and preventing fraud, illegal activities, and activities that violate our policies, and resolving technical issues; and for other purposes disclosed to you at the time you provide your information, or otherwise with your consent.	We may disclose this type of information to: • Subsidiaries, Affiliates and Sister Companies • Your Company • Service Providers • Third parties or affiliated companies when you agree to or direct that we share your information with them • Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition • Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) • Third party analytics companies	Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Characteristics of protected classifications under CA or federal law (such as gender and age)	We may collect this type of information from: • You • Third party social media companies, • Third party business partners and data providers	We may collect this type of information from: • You • Third party social media companies, • Third party business partners and data providers	We may collect this type of information from: • You • Third party social media companies, • Third party business partners and data providers	We do not sell or share for cross context behavioral advertising.
Commercial information (such as product type or services or applications purchased, obtained, or considered or other purchasing or consuming histories or tendencies)	We may collect this type of information from: • You • Your Company • Affiliated and Sister Companies • Cookies and Tracking Technologies, • Third party social media companies, • Third party business partners and data providers	We may use this type of information to: tailor your experience on the Properties; to determine which products and services we offer may be of interest to you; to manage and develop our business relationship with you and the company for which you work; to allow you to participate in the Properties and features offered through the Properties; to process your registration with the Properties, including verifying that your personal information is active and valid; to tailor content, recommendations, and offers we display to you, both on the Properties and elsewhere online; to provide you with you with customer service, support and answer questions or other requests; operate and protect the Properties from errors and misuse, investigating and preventing fraud, illegal activities, and activities that violate our policies, and resolving technical issues; and for other purposes disclosed to you at the time you provide your information, or otherwise with your consent.	We may disclose this type of information to: • Subsidiaries, Affiliates and Sister Companies • Your Company • Service Providers • Third parties or affiliated companies when you agree to or direct that we share your information with them • Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition • Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) • Third party analytics companies	We do not sell or share for cross context behavioral advertising.
Internet or other electronic network activity information (such as information about the web browser and operating system you are using, the website or ad that referred you to our Services, or areas within our Properties that you visited.)	We may collect this type of information from: • You • Your Company • Affiliated and Sister Companies • Cookies and Tracking Technologies, • Third party social media companies • Third party business partners and data providers	We may collect this type of information from: • You • Your Company • Affiliated and Sister Companies • Cookies and Tracking Technologies, • Third party social media companies • Third party business partners and data providers	We may disclose this type of information to: • Subsidiaries, Affiliates and Sister Companies • Your Company • Service Providers • Third parties or affiliated companies when you agree to or direct that we share your information with them • Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition • Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) • Third party analytics companies	Third party advertising, analytics, and similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

Additional Notice to California Residents

If you are a California resident, you have the right to receive: a) information identifying any third party companies to whom Crispin may have disclosed, within the past year, personal information pertaining to you and your family for that company’s direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to Privacy@am.sony.com. Requests must include a reference to “Your California Privacy Rights – Crispin”.

14. Further Information for Individuals in the EEA, UK, and Switzerland

What rights do I have in relation to my personal information?

You may be entitled to ask Crispin 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 information 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 information is optional.

We hope that we can satisfy queries you may have about the way we process your information. 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 privacy@am.sony.com. If you have unresolved concerns you also have the right to complain to your local data protection authorities.

The data controller for your information is Crispin Corporation.

Where information is transferred outside the EEA, UK, or Switzerland and where this is to an affiliate or vendor in a country that is not subject to an adequacy decision by the commission, data is adequately protected by approved transfer mechanism, such as standard contractual clauses. A copy of the relevant mechanism can be provided for your review on request.