SONY PICTURES RELEASING INDIA PRIVACY POLICY

Posted 4 December 2012.

PLEASE READ. YOUR USE OF THIS SITE OR FEATURE IS SUBJECT TO THE FOLLOWING PRIVACY POLICY STATEMENT AND THE TERMS OF USE .

NOTICE

This Privacy Policy applies to the web sites, web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," alternative reality worlds or features, or other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology, manner or means (each a "Site"). The Sites are offered by Sony Pictures Releasing of India Ltd., 503, Alpha, Hiranandani Gardens, Main Street, Powai, Mumbai 400076, and/or its subsidiary or affiliated companies in India (collectively, "SPRI," or "we," "us," and "our").

Please read this Privacy Policy carefully as your use of this Site constitutes your consent to the processing of your Personal Information as described in the Policy. If you are younger than 18 years old of age, and you wish to provide us with your Personal Information to participate in a promotion or contest, you must read this Privacy Policy with your parent or guardian.

SUMMARY OF KEY POINTS

  • We use Personal Information to allow you to participate in the features on the Site, to process your registration, and to provide you with other requested content related to our movies and other offerings. Click here to learn more.

  • We provide interactive features that engage with third party social media sites, such as Facebook and Twitter. Any data that we obtain about your use of such features is subject to this Privacy Policy. Any data that the social media sites gather about you is subject to your terms with them. Click here to learn more.

  • We use cookies and other technologies to track the use of our Service. To learn about opportunities to choose not to allow cookies, click here .

  • If you are under 18 years old, you must obtain the permission of your parent or guardian before participating in a contest or engaging in other activities. The only exceptions are if you simply sign up for a newsletter or request certain basic content. Click here to learn more.

  • We disclose your Personal Information publicly when you post User-Generated Content on the Site. We also disclose Personal Information when you request or agree to such sharing with business partners or other third parties, when we engage a third party to process data on our behalf, when such sharing is required by law, or in certain other situations. Click here to learn more.

  • This Site may be hosted on web servers in India. Your use of the Site constitutes your consent to the transfer of Personal Information to India, a jurisdiction that may not provide the same level of data protection as your home country. Click here to learn more.

1. INFORMATION COVERED BY THIS PRIVACY POLICY

INFORMATION YOU PROVIDE

We may collect Personal Information, including your name, email or street address, date of birth, telephone number, your preferences and interests, or other information you provide to us or grant us access to ("Personal Information") when you register for newsletter, communicate with us, or take part in interactive games, features or competitions. We may also collect any photographs, video images or other user generated content that you may upload to the Site ("User-Generated Content" or "UGC"). On providing such information, you consent to us collecting, using, transferring, processing any Personal Information relating to you, so collected by us.

AUTOMATIC INFORMATION COLLECTION

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

We also automatically collect your IP address or other unique identifier for the computer, mobile device, technology or other device (collectively, "Device") you use to access the Site. A unique identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by this number ("Device Identifier"). Some mobile service providers may also provide us with the physical location of the Device used to access the Site.

THIRD PARTY INTERACTIVE FEATURES

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

COOKIES AND OTHER TRACKING TECHNOLOGIES

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

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

HOW WE USE COOKIES AND WEB BEACONS

SPRI may use cookies and web beacons for a number of purposes, including to:

  • Provide general internal and customer analytics.

  • Study traffic patterns in order to improve website performance, to customize the user experience, and to better match the users' interests and preferences. For example, SPRI keeps track of the domains from which people visit, and also measures visitor activity on SPRI websites. However, these tracking records are performed and maintained in ways that keep the data non-identifiable.

  • Keep track of preferences you specify while you are using SPRI products or services.

  • Support security measures, such as requiring re-login into a SPRI product or service after a certain amount of time has elapsed.

  • If you login to our products through the Site, cookies can also be used to save the username so that we can process the saved login information and quickly log you into the product.

  • Assist in identifying possible fraudulent activities.

  • Tell if an email has been opened and acted upon.

CONTROLLING OUR USE OF COOKIES

  • You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

  • For analytics services, we may use Omniture, a web analysis service provided by Adobe which includes session cookies and beacons. If you do not wish to allow your session visit information on the Site to be aggregated and analyzed by us, you may click here to opt-out.

  • The Adobe Flash Player is an application and web tool that allows rapid development of dynamic content. Flash (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies. SPRI employs Adobe Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. SPRI does not use Flash cookies to serve interest-based advertising. Flash cookies are managed through the Flash Player Settings Manager, which is a different interface than the one provided by your web browser. This Settings Manager lets you manage global privacy settings, storage settings, security settings, and automatic notification settings. Beginning with Flash Player 10.3, the Flash Player Settings Manager can be accessed locally on your computer: in the Control Panel on Windows and in System Preferences on Mac. Users of other operating systems and earlier versions of the Flash Player should manage their global privacy settings using the Flash Player Settings Manager provided online from Adobe: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager06.html

  • This Site may also use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses cookies, text files that are stored on your Device and allow an analysis of your use of the Site. If Google Analytics is used, the information generated by the cookie about your use of the Site (including the IP address) will be transferred to and stored on a server of Google in the US. Google will use such information to analyze your use of the Site, to create reports about the Site activities for SPRI and to provide further services associated with the use of the Site and the internet. Furthermore, Google may transfer such information to third parties, to the extent legally required or if such third parties process the data on behalf of Google. In no event will Google associate your IP address with other information of Google. By using this Site, you consent to the processing of your information collected by Google as described above and for the purposes described above. Google Analytics can be disabled through this link: http://tools.google.com/dlpage/gaoptout

  • For further information about cookies you can visit www.allaboutcookies.org . If you choose to decline cookies, you may not be able to login or use other interactive features of our Sites and features that depend on cookies.

2. SPECIAL NOTICE REGARDING CHILDREN UNDER 18

SPRI recognizes the sensitivity of personally identifiable information concerning children under the age of 18 and therefore provides this special notice. SPRI will not knowingly collect, maintain, or disclose any personally identifiable information from a child under 18 without first obtaining consent from that child's parent or guardian.

If you are the parent or guardian of a child under 18, and your child would like to participate in certain Services (and SPRI has chosen to make such Services available to children in this age group), your child will be prompted to print out a form for you to complete and mail in to SPRI. The form will list the information required from both parent/guardian and child, as well as the intended uses of the information. SPRI will only collect information that is reasonably necessary for your child to participate, and SPRI will not share your child's personally identifiable information with any third party (except where express consent has been given under the form by the parent/guardian, regarding transfer of such information for purposes of fulfillment by a third party that has agreed to protect the information in accordance with this Privacy Policy), unless you specifically consent, or any other applicable law. You may also subsequently revoke your consent and request that your child's information be removed from SPRI's active list. Please refer to the form for instructions and further information.

If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her personally identifiable information without your permission or consent, SPRI will make reasonable efforts to remove the information from its active list, at your request. To request the removal of your child's information, please send e-mail to SPE_PrivacyIndia@spe.sony.com and be sure to include in your message the same name and password and/or email address that your child submitted.

SPRI encourages parents and guardians to spend time online with their children to become familiar with the types of content available on the SPRI websites and the Internet generally.

3. HOW WE USE YOUR INFORMATION

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

4. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share Personal Information with the following parties:

When You Agree To Have Your Personal Information Shared

While on our Site, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your Personal Information with a third party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party. You also may specifically request, sometimes through your use of an interactive feature, a widget or an application, that we share your Personal Information with a third party and we will typically do so under those circumstances. In addition, if you choose to register for a promotion, such as a competition, prize draw or contest, your Personal Information may be disclosed to third parties for purposes of the administration of such promotion.

Personal Information That You Disclose Publicly on the Site

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

Third Parties Providing Services on Our Behalf

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

Affiliate Sharing and Business Transfers

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

Legal Protections and Other Disclosures

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

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

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

6. CONSENT TO PROCESSING IN THE UNITED STATES OF AMERICA

The Site is hosted in the United States of America, where the privacy laws may not provide an equivalent level of protection to those in your home country. By using the Site, or by providing SPRI with any personally identifiable information, you fully understand and unambiguously consent this Privacy Policy and to the collection, storage, and processing of such information in the United States.

7. AMENDING OR REMOVING YOUR PERSONAL INFORMATION, CONTROLLING MARKETING COMMUNICATIONS, AND PRIVACY QUESTIONS

You have the right to access your Personal Information held by us and, if necessary, have it amended or deleted. You can also request not to receive email, SMS, and MMS marketing communications from us. You may opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. If you sign up to receive SMS or MMS messages, you may unsubscribe from any SMS or MMS messages received by replying "STOP." Please note that we may still need to send you certain communications relating to your account or use of the Sites and these transactional account messages may be unaffected if you choose to opt-out from marketing communications.

For more details or any privacy questions please contact us by email at SPE_PrivacyIndia@spe.sony.com or write to us at:

Sony Pictures Releasing India Ltd
503, Alpha, Hiranandani Gardens,
Main Street, Powai, Mumbai 400076

8. SPRI COMMITMENT TO DATA SECURITY

SPRI RESPECTS YOUR PRIVACY AND IS COMMITTED TO PROTECTING PERSONALLY IDENTIFIABLE INFORMATION THAT YOU PROVIDE IN CONNECTION WITH YOUR USE OF ITS SITES.

SPRI takes reasonable and appropriate precautions to protect your personally identifiable information from unauthorized disclosure and to prevent possible security breaches in its Sites and customer databases. However, in order to facilitate more effective data protection, SPRI urges you to take steps to keep your information safe by memorizing any passwords or keeping them in a safe place (separate from your account information), logging out of any user accounts, and closing your Web browser.

9. NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY

We reserve the right to change the terms of this Privacy Policy at any time, by prominently posting notice of the amendment on this Site. To the extent permitted by applicable law, such changes will be applicable from the time they are posted.

Effective Date: This Privacy Policy was updated 4 December 2012 and is effective as of that date.

Sony Pictures Releasing of India Ltd.