Adobe Privacy Policy

DATED 2016-09-28 · VERSION 20161008_rev01 · COMPARED WITH 20160708_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20160708_rev01 to 20161008_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+Last updated: June 16, 2016
+Last updated: September 28, 2016
+The Adobe Privacy Policy describes the privacy practices of Adobe's apps and websites. If you are a resident of North America, your relationship is with Adobe Systems Incorporated, a United States company, and the laws of California and the laws of the United States apply.
+The Adobe Privacy Policy describes the privacy practices of Adobe's apps and websites. If you are a resident of North America, your relationship is with Adobe Systems Incorporated (Adobe U.S.) and the laws of California and the United States apply.
+If you reside outside of North America, your relationship is with Adobe Systems Software Ireland Limited, which is the controller with regard to your personal information collected by Adobe, and the laws of Ireland apply. Please note that in order to use our apps and websites, you authorize Adobe to transfer your personal information across national borders and to other countries where Adobe and its partners operate, including the United States. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in your country. We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections. For more information, please see the section "[Does Adobe transfer my personal information across national borders?](https://www.adobe.com/privacy/policy.html)"
+If you reside outside of North America, your relationship is with Adobe Systems Software Ireland Limited (Adobe Ireland), which is the controller with regard to your personal information collected by Adobe, and the laws of Ireland apply. Please note that in order to use our apps and websites, you authorize Adobe to transfer your personal information across national borders and to other countries where Adobe and its partners operate, including the United States. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in your country. We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections. For more information, please see the section "[Does Adobe transfer my personal information across national borders?](https://www.adobe.com/privacy/policy.html)"
 ##### What does this privacy policy cover?
+This privacy policy describes the privacy practices of Adobe's websites, as well as our desktop apps and mobile apps that include a link to this policy (in this policy, we refer to our desktop apps and mobile apps together as "apps"). Note that "websites" include web-based services such as Behance, as well as the web-based aspects of the Creative Cloud, Document Cloud, and other Adobe offerings. This privacy policy also applies to Adobe's marketing and advertising practices. Additional privacy-related information is provided for certain [Adobe apps and websites](https://www.adobe.com/privacy/policies.html). Please also see the [Adobe Terms of Use](https://www.adobe.com/legal/terms.html) and any additional Terms of Use or [Product License Agreements](https://www.adobe.com/legal/licenses-terms.html) that may apply to the app or website you are using. Companies acquired by Adobe may operate under their own privacy policies ([learn more](https://www.adobe.com/privacy/policies.html)).
+This privacy policy describes the privacy practices of Adobe's websites, as well as our desktop apps and mobile apps that include a link to this policy (in this policy, we refer to our desktop apps and mobile apps together as "apps"). Note that "websites" include web-based services such as Behance, as well as the web-based aspects of the Creative Cloud and Document Cloud. This privacy policy also applies to Adobe's marketing and advertising practices. Additional privacy-related information is provided for certain [Adobe apps and websites](https://www.adobe.com/privacy/policies.html). Please also see the [Adobe Terms of Use](https://www.adobe.com/legal/terms.html) and any additional Terms of Use or [Product License Agreements](https://www.adobe.com/legal/licenses-terms.html) that may apply to the app or website you are using. Companies acquired by Adobe may operate under their own privacy policies ([learn more](https://www.adobe.com/privacy/policies.html)).
 ##### What information does Adobe collect about me?
 **Adobe ID, registration, and customer support**
 When you register to use an Adobe app or website, create an Adobe ID, or contact us for support or other offerings, Adobe collects information that identifies you. This includes information such as your name, company name, email address, or payment information. We may also sometimes collect other information that does not identify you, such as which types of apps you're interested in. Some of this information is required and other information is optional. For [student and teacher editions](http://www.adobe.com/education/students/how-to-buy-eligibility.edu.html) of our apps, information regarding your eligibility is required. To help keep our databases current and to provide you the most relevant content and experiences, we may combine information provided by you with information from other sources, in accordance with applicable law. For example, from these sources, we may learn about the size, industry, and other information about the company you work for.
 Your personal information and files are stored on Adobe's servers and the servers of companies we hire to provide services to us. Your personal information may be transferred across national borders because we have servers located worldwide and the companies we hire to help us run our business are located in different countries around the world.
 ##### Does Adobe transfer my personal information across national borders?
 We may transfer your personal information across national borders to other countries in compliance with applicable laws.
+As mentioned above, if you reside outside of North America, your relationship is with Adobe Systems Software Ireland Limited (Adobe Ireland). For these individuals, when we transfer your personal information from the European Economic Area (EEA) to a non-EEA country, we do so using a variety of legal mechanisms including Standard Contractual Clauses, while also relying on your consent.
+If you reside outside of North America, your relationship is with Adobe Ireland. When Adobe Ireland transfers your personal information from the European Economic Area (EEA) to a non-EEA country, we rely on one or more of the following legal mechanisms: the EU-U.S. Privacy Shield, Standard Contractual Clauses, and your consent. For more information about the certification of Adobe U.S. to the EU-U.S. Privacy Shield, including the scope of our certification, please see [Privacy Shield/European data transfers](https://www.adobe.com/privacy/eudatatransfers.html).
 If the content or data that you store on Adobe apps or websites contains the personal information of individuals from the EEA , you agree that you have the legal authority to transfer the personal information to Adobe, including the transfer to countries such as the United States where the privacy protections and rights of authorities to access personal data may not be equivalent to those in the EEA.
+The U.S. Department of Commerce continues to administer the U.S.-EU Safe Harbor program despite a European Court of Justice decision that invalidated Safe Harbor in October 2015. Adobe Systems Incorporated (our U.S. company) is retaining its Safe Harbor certification pending U.S. and EU government action on a replacement program.
 The information above applies to Adobe users that have agreed to the Adobe Privacy Policy. More information is available for our business customers that want to learn more about [European data transfers](https://www.adobe.com/privacy/eudatatransfers.html).
 ##### How can I review or update my personal information or close my Adobe ID account?
 Under the law of some countries, you may have the right to access the information Adobe holds about you, correct mistakes in that information, and to delete personal information that we no longer have business reasons for retaining. Many of our websites and apps allow you to edit your personal information by accessing the "[my account](https://accounts.adobe.com/)," "my profile," or a similar feature of the app or website you are using. Likewise, you can delete files or photos you have stored in our websites and apps by logging in and using the deletion functions they make available.