Effective: June 1, 2019
1. Collection of Information
1.1 Information You Provide To Crispin
While Crispin does not generally require that you provide us with personal data 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 data 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 data about you, we will treat the combined information as personal data. We may also de-identify personal data, 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.
Individuals Younger Than Age 13. (For US residents)
The Properties are directed to a general audience. We do not knowingly collect personal data from anyone younger than the age of 13, and Crispin will delete any personal data later determined to have been inadvertently collected from a user younger than age 13.
1.2 Information Crispin Collects Automatically
In addition to any personal data or other information that you choose to provide to us, whenever you visit or interact with the Properties, Crispin 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 data.
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, Flash 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, such as Adobe Flash, 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. For example, a Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Cookies, Flash 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. You may refuse or remove some or all of these cookie and local storage technologies; however, if you choose to do so, some features of our Properties may not function properly.
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.
2. Uses of the Personal Data Crispin Collects
Crispin will use the information it collects, including your personal data:
- 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 customer service, support and answer questions or other requests;
- for other purposes disclosed to you at the time you provide your information; and
With your consent, we may send you special offers from us, our advertisers, or third-party business partners.
3. When and With Whom Crispin May Share Information Collected
3.1 Non-Identifiable Information.
We may share non-identifiable information, such as aggregate user statistics, demographic information, de-identified information and Usage Information with third parties in our discretion, including tailoring promotions, advertising and communications we present to you.
3.2 Personal Data.
We may share your personal data as specifically disclosed at the time you provide your personal data and in the following circumstances:
To Other Sony Group companies.
To Third-Party Service Providers Providing Properties On Crispin’s Behalf.
We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your personal data 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 data 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.
We may share your personal data 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 data, is one of the key business assets in the transaction. In such a case, your personal data may be one of the business assets we transfer. Hence, Crispin reserves the right to disclose and transfer user information, including personal data, in connection with any activity and/or transaction described above. By providing your personal data, you agree that we may transfer such information to the acquiring entity without your further consent.
Legal Protections and Law Enforcement.
We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifier (including IP address)), to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (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.
4. Analytics and Similar Third Party Properties and Your Choices
We may use a variety of companies to perform advertising and analytics Properties including:
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, but is not limited to, pages visited, interaction on pages, device and browser type, and the geographic location.
We may also use third party services in order to obtain demographic and interest reports. We utilize first-party cookies or other first-party identifiers, and third-party cookies (such as advertising cookies) or other third-party identifiers together to analyze your other information and your interest. If you choose to opt out of cookies, please disable cookies in your browser settings.
5. “Do Not Track” 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. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Properties do not currently interpret, respond to or alter their practices when they receive Do Not Track signals. Please note that third parties may collect personal information about your online activities over time and across different websites when you visit our website or other online websites and Properties. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
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 data. 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.
7. Notice to California Residents
Your California Privacy Rights: If you are a California resident, you have the right to receive once per calendar year: (a) information identifying any third party(ies) to whom Crispin may have disclosed, within the preceding calendar year, your personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information free of charge, please write to us at: email@example.com
or write to us at: Personal Information Management Office, Sony Electronics Inc., 115 W. Century Rd., Suite 250, Paramus, NJ 07652. Crispin will respond to these requests within thirty (30) days. Requests that come to Crispin by other means may result in a delayed response. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Crispin uses commercially reasonable safeguards to help protect and secure your personal data, 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 data 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.
9. Consent to Processing
By providing any Personal Information to Crispin, all persons, including without limitation persons in the member states of the European Union, 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, and understand and acknowledge their consent, notwithstanding that some governmental authorities may consider the level of protection of such data in the United States not equivalent to that required within the European Union or any other jurisdiction. By visiting the websites and using the Properties, or providing us with any information, you fully understand and unambiguously consent to the transfer, processing and/or storage of your information in another country, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
10. How Long We Hold Data
Where you are a customer, Crispin will keep your information for the length of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. For data about your visits to our websites or applications, Crispin will retain this data in accordance with our retention policy. Laws may require Crispin to hold certain information for specific periods. In other cases, Crispin may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.
12. How to Contact Us
Personal Information Management Office
Sony Electronics Inc.
115 W. Century Rd., Suite 250
Paramus, NJ 07652
You must include your name, mailing address, a reference to Crispin and the subject matter of your correspondence in any email or mailing that you send to us. If this information is not provided, our response may be delayed.
If you wish to unsubscribe from receiving commercial electronic messages, you may contact us as described above or click on the unsubscribe link here:
Please note that we reserve the right to send you certain communications relating to your account or your use of the Properties or as otherwise permitted by applicable law, and these transactional account messages and other non-commercial messages may not be affected by your choice to unsubscribe from commercial communications.
13. Further Information for Individuals in the EEA
What rights do I have in relation to my personal data?
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 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 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 firstname.lastname@example.org. Please reference Crispin in your correspondence. 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, and where this is to an affiliate or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request.