Adobe Privacy Policy

DATED 2023-04-20 · VERSION 20230501_rev01 · COMPARED WITH 20230101_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20230101_rev01 to 20230501_rev01

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

+Last updated: December 5, 2022
+Last updated: April 20, 2023
+The Adobe Privacy Policy describes the privacy practices of Adobe's Services and Software (as defined in our General [Terms of Use)](https://www.adobe.com/legal/terms.html) and anywhere we display or reference this policy. If you are a resident of North America, your relationship is with Adobe Inc. (Adobe U.S.) and the laws of California and the United States apply.
+The Adobe Privacy Policy describes the privacy practices of Adobe's Services and Software (as defined in our General [Terms of Use)](https://www.adobe.com/content/cc/us/en/legal/terms-old.html) and anywhere we display or reference this policy.
+If you are a resident of North America, your relationship is with Adobe Inc. (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 (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 Services and Software, you acknowledge that Adobe will 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 the content or information that you store in Adobe Services and Software contains personal information of other individuals, you must be legally permitted to disclose the personal information to Adobe.
 - Services that display or include a reference to this policy;
 - Adobe's marketing, sales, and advertising practices; and
 - The privacy practices of previously acquired companies, unless otherwise noted here.
 Please note that websites and apps provided by some companies acquired by Adobe may operate under their own privacy policies until their privacy practices are integrated with Adobe's privacy practices. For a current list of these companies, click [here](https://www.adobe.com/privacy/policies.html). Additional privacy-related information for certain Adobe Services and Software can be found in the table below:
+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 Services and Software you are using.
+Please also see the [Adobe Terms of Use](https://www.adobe.com/content/cc/us/en/legal/terms-old) and any additional Terms of Use or [Product License Agreements](https://www.adobe.com/legal/licenses-terms.html) that may apply to the Services and Software you are using.
 ### What information does Adobe collect about me?
 **Adobe ID, registration, and customer support**
 When you register to use an Adobe Service, create an Adobe ID, purchase a license to our Services and Software, or contact us for support or other offerings, Adobe collects information that identifies you. This includes:
 - Name;
 - Email address;
 - Telephone number;
 - Postal or Physical Address;
+- Country.
+- Country;
+- Account Password.
 Commercial and transaction information, such as:
 - Payment/billing information (where an app or website is 'paid for');
 - Licenses purchased;
 - Eligibility information (e.g., student or teacher identification for student and teacher editions of apps);
+- Content of and information provided through customer support communications;
+- Content of and information provided through customer support communications (e.g., recorded customer and technical support calls and stored content of your correspondence with us via our website, chat features, phone calls, and other channels);
 - Types of Services and Software of interest.
 Professional, education or other demographic information, such as:
 - Date of birth;
 - Company or school name;
 **Inferred Information**
 To help keep our databases current and to provide you the most relevant content and experiences, we may infer or generate information based on the information we collect or combine information provided by you with information from third party sources, in accordance with applicable law. For example, the size, industry, and other information about the company you work for (where you have provided company name) will be obtained from sources including, professional networking sites and information service providers. We may also infer, generate, or collect and receive information from third parties, including partners, and from publicly accessible sources, for purposes that include to detect, prevent, or otherwise address fraudulent, deceptive or illegal activity, misuse of our Services and Software, security or technical issues, as well as to protect against harm to the rights, property or safety of Adobe and our employees, our users, children, or the public.
 **Adobe Services and Software**
+We collect information you provide to use (e.g., when you access and use our Services and Software) or permit us to collect (e.g., as part of a third-party integration). We also collect or generate information about how you access and use our Services and Software, including when you use a desktop or mobile app feature that takes you online (such as a photo syncing feature). Depending on the Services and Software you access and use, this information may be associated with your device or browser or it may be associated with your Adobe account or content. It includes:
+We collect information you provide to us (e.g., when you access and use our Services and Software) or permit us to collect (e.g., as part of a third-party integration). We also collect or generate information about how you access and use our Services and Software, including when you use a desktop or mobile app feature that takes you online (such as a photo syncing feature). Depending on the Services and Software you access and use, this information may be associated with your device or browser or it may be associated with your Adobe account or content. It includes:
 Analytics or other electronic network activity, such as:
 - IP address;
 - Browser and device information, including browser and device type, settings, unique identifiers, version, language settings, and configuration;
 - Webpage that led you to an Adobe website;
 - Search terms entered into a search engine which led you to an Adobe website;
+- Use and navigation of Services and Software (collected through cookies and similar technologies, or by Adobe servers when you are logged in to the app or website);
+- Use and navigation of Services and Software, including how you interact with Adobe websites (collected through cookies and similar technologies, or by Adobe servers when you are logged into the app or website);
+- Analysis of your use and navigation of the Services and Softare as well as your content.
+- Analysis of your use and navigation of the Services and Software as well as your content
 Professional, Education or other demographic information, such as:
 - Profile information (e.g., account profile, public profile, Behance profile).
 Commercial and transaction information, such as:
 - Content (e.g., documents, photos, videos, activity logs, direct feedback from you, and metadata about your content) which is sent or received using an online feature of Adobe Services and Software, or which is stored on Adobe servers.
 Sensitive personal information, such as:
+- Biometric identifiers or information as defined under US laws (e.g., faceprints and voiceprints from your user Content, as defined in the [Adobe General Terms of Use](https://www.adobe.com/legal/terms.html)) and precise geolocation. Where required by law, we will seek any required permissions from you prior to any such collection. See the "Adobe acting on your behalf" and "How we analyze your content to deliver features requested by you" sections below for more information.
+- Biometric identifiers or information as defined under US laws (e.g., faceprints and voiceprints from your user Content, as defined in the [Adobe General Terms of Use](https://www.adobe.com/content/cc/us/en/legal/terms-old.html)) and precise geolocation. Where required by law, we will seek any required permissions from you prior to any such collection. See the "Adobe acting on your behalf" and "How we analyze your content to deliver features requested by you" sections below for more information.
 The following links provide further information on:
 - [Adobe product improvement program](https://www.adobe.com/privacy/apip.html);
 - [App Diagnostic and Usage Information FAQ](https://www.adobe.com/privacy/app-usage-info-faq.html)
 - [Experience Cloud usage information FAQ](https://www.adobe.com/privacy/experience-cloud-usage-info-faq.html);
 - Adobe products and services licensed by [educational institutions](https://www.adobe.com/privacy/student-policy.html);
 - How Adobe uses [cookies and similar technologies](https://www.adobe.com/privacy/cookies.html); and
 - How Adobe [analyzes your content](https://helpx.adobe.com/manage-account/amr/machine-learning-faq.html) using techniques such as machine learning in order to improve our Services and Software, and how to [opt out](http://www.adobe.com/go/machine_learning_opt_out) of this.
 **Adobe Software activation and automatic updates**
+When you activate your Adobe Software or when you install updates to the Software, we collect analytics or other electronic network activity information, such as:
+- When you activate your Adobe Software or when you install updates to the Software, we collect analytics or other electronic network activity information, such as: your device (manufacturer, model, IP address);
+- your device (manufacturer, model, IP address);
 - the Adobe Software (version, date of activation, successful and unsuccessful updates);
 - your product serial number (e.g., where this is required before you can start using your product).
 You can learn more about app activation [here](https://helpx.adobe.com/uk/x-productkb/policy-pricing/activate-deactivate-products.html).
 **Adobe emails**
 Emails we send you may include a technology (called a [web beacon](https://www.adobe.com/privacy/cookies.html)) that collects Analytics or other electronic network activity, such as whether you have received or opened the email, or clicked a link in the email. If you do not want us to collect this information, you can [opt out of receiving Adobe marketing emails](https://www.adobe.com/privacy/opt-out.html).
 **Adobe online advertising**
+Adobe advertises online in a variety of ways, including displaying Adobe ads to you on other companies' websites and apps and on social media platforms, such as Facebook and LinkedIn. Adobe websites use cookies and similar technologies provided by our own company ([Adobe Experience Cloud](https://www.adobe.com/privacy/experience-cloud.html)) and other companies that allow us to gather additional information to measure and improve the effectiveness of our advertising. We collect Analytics or other electronic network activity information such as:
+Adobe advertises online in a variety of ways, including displaying Adobe ads to you on other companies' websites and apps and on social media platforms, such as Facebook and LinkedIn. Adobe websites use cookies, pixels, and similar technologies provided by our own company ([Adobe Experience Cloud](https://www.adobe.com/privacy/experience-cloud.html)) and other companies that allow us to gather additional information to measure and improve the effectiveness of our advertising. We collect Analytics or other electronic network activity information such as:
 - Which ads are displayed;
 - Which ads are clicked on; and
 - Where the ad was displayed.
 ****Buttons, tools, and content from other companies****
 Adobe Services and Software may include buttons, tools, or content that link to other companies' services (for example, a Facebook "Like" button). We may collect information about your use of these features, such as content "liked" and address information in Google Maps. In addition, when you see or interact with these buttons, tools, or content, or view an Adobe web page or app containing them, some information from your browser may automatically be sent to the other company. Please read that company's privacy policy for more information.
 Adobe websites may implement Google reCAPTCHA Enterprise to help prevent spam and abuse. reCAPTCHA Enterprise collects hardware and software information, such as device and application data, and sends it to Google for purposes of providing, maintaining, and improving reCAPTCHA Enterprise and for general security purposes. Your use of reCAPTCHA Enterprise is subject to Google's [Privacy Policy](https://policies.google.com/privacy) and [Terms of Use](https://policies.google.com/terms).
 **Adobe social networking pages and social sign-on services**
+You can sign in to some Adobe Services and Software using a social networking account, such as a Facebook account. Where you give appropriate permissions, we will receive contact and identifier information about you from your social networking account, such as name, country, and basic demographic information.
+You can sign into some Adobe Services and Software using a social networking account, such as a Facebook account. Where you give appropriate permissions, we will receive contact and identifier information about you from your social networking account, such as name, country, and basic demographic information.
 Adobe has its own pages on many social networking sites (for example, the Adobe® Photoshop® team's Facebook page). We will collect information which you have made publicly available on your social networking account, such as name and interests in our products and services, when you interact with our social networking pages. The social networking sites may provide statistics and insights to Adobe which help us understand the types of actions that people take on our pages. Where applicable, Adobe and the social media site(s) have entered into an arrangement which determines our respective responsibilities.
 You can learn more about Adobe's practices with respect to social networking pages and account sign-on services [here](https://www.adobe.com/privacy/social-networking.html).
 **Adobe acting on your behalf**
+In certain instances, Adobe is acting only on your behalf for personal information collected and processed by our services (for example, for the address book contacts shared by users when entering recipient information). In such cases, Adobe is acting only on your instructions in order to facilitate the Service requested by you, and you will be responsible for the information shared. In these instances, we will inform you through in-app notifications or other in-time communications. If you submit any information relating to other people to us or to our service providers in connection with your use of Adobe Services and Software, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
+In certain instances, Adobe is acting only on your behalf for personal information collected and processed by our services (for example, for the address book contacts shared by users when entering recipient information). In such cases, Adobe is acting only on your instructions in order to facilitate the Service requested by you, and you will be responsible for the information shared. In these instances, we will inform you through in-app notifications or other in-time communications. If you submit any information relating to other people to us or to our service providers in connection with your use of Adobe apps or websites, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
 **How we analyze your content to deliver features requested by you**
+Adobe offers certain features that let you edit and organize your photographs, videos, and other types of content using characteristics like face and voice (e.g., you can group similar faces, places, and image characteristics within your collection), and such characteristics may be considered biometric identifiers or biometric information under certain US laws or other applicable privacy laws. When you choose to use these features, Adobe is acting only on your instructions in order to facilitate the Service requested by you. These features are off by default and, should you choose to enable them, you can always disable these features. Where we process biometric identifiers or biometric information to deliver a feature requested by you, we delete this information once you turn off the feature, unless otherwise specified in the Software or Services.
+Adobe offers certain features that let you edit and organize your photographs, videos, and other types of content using characteristics like face and voice (e.g., you can group similar faces, places, and image characteristics within your collection), and such characteristics may be considered biometric identifiers or biometric information under certain US laws or other applicable privacy laws. When you choose to use these features, Adobe is acting only on your instructions in order to facilitate the service requested by you. These features are off by default and, should you choose to enable them, you can always disable these features. Where we process biometric identifiers or biometric information to deliver a feature requested by you, we delete this information once you turn off the feature, unless otherwise specified in the Software or Services.
+**Visiting our Physical Offices**
+When you visit an Adobe office, we will collect Identifiers and Contact information such as your name, company name, and email address; and Audio, electronic, visual, or similar information including facial images and voice information such as from CCTV video or voice recordings and photos.
 ### How does Adobe use the information it collects about you, and what are the legal bases for these uses?
 Adobe uses the information we collect about you for the following purposes:
 - To fulfill a contract, or take steps linked to a contract: this is relevant where you register to use an Adobe app or website (whether paid, or as a free trial). This includes:
     - Providing you with the Adobe Services and Software for which you have registered, and any other services or products that you have requested;
     - Verifying your identity;
     - Processing payments;
     - Sending you necessary communications (for example, related to payments or expiration of your subscription); and
     - Providing customer service or support.
 - As required by Adobe to conduct our business and pursue our legitimate interests, in particular:
     - Providing you with the Adobe Services and Software for which you have registered and any other products and services you have requested;
+    - Analyzing your use and measuring effectiveness of our Services and Software to better understand how they are being used so we can improve them and engage and retain users;
+    - Analyzing your use and measuring effectiveness of our Services and Software, including recordings, to better understand how they are being used so we can improve them and engage and retain users;
     - Sending you information about Adobe products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes (where your consent is not required);
     - Analyzing your use and navigation of our Services and Software, your content, your profile information, and your interaction with our communications, to tailor and customize the Services and Software, and marketing communications ([learn more](https://www.adobe.com/privacy/marketing.html)) (where your consent is not required);
+    - Analyzing your use and navigation of our Services and Software as well as your content and metadata about your content through techniques such as machine learning in order to detect and prevent fraudulent, deceptive, or illegal activity, or misuse of our Services and Software, and improve our Services and Software and the user experience (where your consent is not required);
+    - Analyzing your use and navigation of our Services and Software as well as your content and metadata about your content through techniques such as machine learning in order to detect and prevent fraudulent, deceptive, or, illegal activity, or misuse of our Services and Software, and improve our Services and Software and the user experience (where your consent is not required);
     - Diagnosing problems in our Services and Software;
+    - Detecting, preventing, or otherwise addressing fraudulent, deceptive, or illegal activity and misuse of Services and Software, security or technical issues, as well as protecting against harm to the rights, property or safety of Adobe, our users, or the public;
+    - Detecting, preventing, or otherwise addressing fraudulent, deceptive, or illegal activity, and misuse of Services and Software, security or technical issues, as well as protecting against harm to the rights, property or safety of Adobe, our users, or the public;
     - Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);
     - Investigating and responding to any comments or complaints that you may send us;
+    - Checking the validity of the sort code, account number and card number you submit if you use a credit or debit card for payment, in order to prevent payment fraud or other illegal or deceptive payment practices (we use third parties for this - see "Does Adobe disclose my personal information to others?" below);
+    - Checking the validity of the sort code, account number, and card number you submit if you use a credit or debit card for payment, in order to prevent payment fraud or other illegal or deceptive payment practices (we use third parties for this - see "Does Adobe disclose my personal information to others?" below);
     - Sharing account information registered under a business email address with employers for account migration purposes;
     - Combining with other data we may have about how you interacted with our products and services when logged out or logged in, in order to provide a more seamless experience, show you the most relevant content and services, and for marketing purposes, with your consent where required;
     - If we merge with or are acquired by another company, sell an Adobe website, app, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to the prospective purchaser, our advisers and any other prospective purchaser's advisers and will be one of the assets that is transferred to the new owner; and
     - In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with government agency requests, legal process or litigation).
 Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. In such cases, we will cease processing information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
 ### Does Adobe disclose my personal information to others?
 **Disclosing to other Data Controllers**
 We will disclose your personal information within the Adobe family of companies for the purposes identified above (see a list of [Adobe entities](https://www.adobe.com/about-adobe/contact/offices.html) and our [acquired companies](https://www.adobe.com/privacy/policies.html)).
+We will also disclose your personal information with other third-party data controllers with your consent (where necessary) or to provide any product or service you have requested (e.g., third-party integrations). The types of third parties your information may be disclosed to include: our resellers and other sales and advertising partners, retailers, advertisers, ad agencies, advertising networks and platforms, information service providers, fraud monitoring and prevention providers, and publishers. In some cases, in order to show you more relevant ads, we disclose with social media platforms and other advertising partners, information about actions you take on our websites and apps, such as which pages you visit and which ads you saw. These parties may be joint controllers for this processing. More information is available [here](https://www.adobe.com/privacy/marketing.html).
+We will also disclose your personal information with other third-party data controllers with your consent (where required by applicable law) or to provide any product or service you have requested (e.g., third-party integrations). Third-party data controllers may also use Adobe products and services to collect and process your personal information. If you are using an email address that is associated with a business domain (e.g., yourname@businessname.com) to access Adobe's Services and Software, or if you were invited to use the Services and Software by a business, we may provide your personal information to that business.
+Third-party data controllers may also use Adobe products and services to collect and process your personal information. If you are using an email address that is associated with a business domain (e.g., yourname@businessname.com) to access Adobe's Services and Software, or if you were invited to use the Services and Software by a business, we may provide your personal information to that business.
 **Disclosing for Fraud Prevention, Safety and Security Purposes**
 We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.
 Additionally, we will disclose personal information to companies, organizations, government authorities, or individuals outside of Adobe if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to detect, prevent, or protect against such fraudulent, deceptive, or illegal activity, misuse of our Services and Software, or security or technical issues, or where it is reasonably necessary to protect from harm the rights, property or safety of Adobe and our employees, our users, children, or the public as required or permitted by law.
 **Disclosing to Data Processors**
+We will also disclose your personal information to companies that help us run our business by processing personal information on behalf of Adobe for the purposes identified above. Such companies include providers of customer support services, payment processing services, fraud monitoring and prevention, detecting and preventing deceptive or illegal activity or misuse of our Services and Software, email, social media, and other marketing platforms and service providers, and hosting services. We require these companies to protect your personal information consistent with this Privacy Policy.
+We will also disclose your personal information to companies that help us run our business by processing personal information on behalf of Adobe for the purposes identified above. Such companies include providers of customer support services (including those that record or store communications), providers of analytics technologies that record and analyze your interaction with our websites to help us improve your experience including session replay partners, payment processing services, fraud monitoring and prevention, detecting and preventing deceptive or illegal activity or misuse of our Services and Software, email, social media, and other marketing platforms and service providers, and hosting services. We have entered into agreement with these companies as required by applicable law and require these companies to protect your personal information consistent with this Privacy Policy.
 **Other Information Disclosure**
 Adobe may also disclose your personal information:
 - When you agree to the disclosure;
 - When we have a good faith belief that we are required to provide information in response to a subpoena, court order, or other applicable law or legal process ([learn more](https://www.adobe.com/legal/lawenforcementrequests.html)), or to respond to an emergency involving the danger of death or serious bodily harm;
 - If we merge with or are acquired by another company, sell an Adobe website, app, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to the prospective purchaser, our advisers and any prospective purchaser's advisers and will be one of the assets that is transferred to the new owner.
 We may disclose or publish aggregate information that doesn't specifically identify you, such as statistical information about visitors to our websites or statistical information about how customers [use the Adobe Experience Cloud](https://www.adobe.com/privacy/experience-cloud.html).
 ### Is my personal information displayed anywhere on Adobe's websites or applications?
 There are several places within Adobe's Services and Software that allow you to post comments, upload pictures, participate in message boards or chats, engage with blogs, share technical information, or submit other content for others to see. Sometimes you can limit who can see what you share, but there are some places where what you share can be seen by the general public or other users of the service. Such information can appear in search engine results or through other publicly available platforms and can be "crawled" or searched by third parties. For example, when users post content on message boards, online chats, blogs, and Community Forums, the information posted by the user will become public. Some online content may remain accessible publicly even after Adobe fulfils a request to delete the poster's personal information.
+Please be careful when you share your personal information. Do not share anything you wouldn't want publicly known unless you are sure you are posting it within an app or website that allows you to control who sees what you post. Please note that when you post messages on certain user forums on our websites and app, your email address or name and/or profile photo may be included and displayed with your message. You can find more information about managing your public profile [here](https://helpx.adobe.com/manage-account/using/edit-adobe-account-personal-profile.html/).
+Please be careful when you share your personal information. Do not share anything you wouldn't want publicly known unless you are sure you are posting it within an app or website that allows you to control who sees what you post. Please note that when you post messages on certain user forums on our websites and app, your email address or name and/or profile photo may be included and displayed with your message. You can find more information about managing your public profile [here](https://helpx.adobe.com/manage-account/using/edit-adobe-account-personal-profile.html/). To remove content you have shared on our Services and Software, please use the same feature you used to share the content. If another user invites you to participate in shared viewing, editing, or commenting of content, you may be able to delete your contributions, but usually the user who invited you has full control. If you have questions or concerns about this, please [contact us](https://www.adobe.com/go/privacyinquiry).
+To remove content you have shared on our Services and Software, please use the same feature you used to share the content. If another user invites you to participate in shared viewing, editing, or commenting of content, you may be able to delete your contributions, but usually the user who invited you has full control. If you have questions or concerns about this, please [contact us](https://www.adobe.com/go/privacyinquiry).
 ### Is my personal information secure?
 We work hard to protect your personal information. We employ administrative, technical, and physical security controls where appropriate, such as encryption, 2-step verification, and appropriate contractual confidentiality obligations for employees and contractors.
 ### Where does Adobe store my personal information?
 Your personal information and files are stored on Adobe's servers and the servers of companies we engage to provide services to us.
 ### Does Adobe transfer my personal information across national borders?
+The main locations where we process your personal information are the US and India, but we also transfer personal information to all other countries in the world where our Services and Software are available. We carry out these transfers in compliance with applicable laws - for example, by putting data transfer agreements in place to help protect your personal information.
+The main locations where we process your personal information are Ireland, the US and India, but we also transfer personal information to all other countries in the world where our Services and Software are available. We carry out these transfers in compliance with applicable laws - for example, by putting data transfer agreements in place to help protect your personal information.
 If you reside outside of North America, your relationship is with Adobe Ireland. Where Adobe Ireland transfers your personal information to a country which is not within the EEA and is not subject to an adequacy decision by the EU Commission, we rely on one or more of the following legal mechanisms: European Commission approved Standard Contractual Clauses and/or your consent in certain circumstances. A copy of the relevant mechanism can be provided for your review upon request, using the contact details provided at the end of this Privacy Policy. For more information about how Adobe Ireland transfers European personal information, please see [Cross-border data transfers](https://www.adobe.com/privacy/eudatatransfers.html).
 The information above applies to Adobe users who are consumers. More information is available for our business customers that want to learn more about [Cross-border data transfers](https://www.adobe.com/privacy/eudatatransfers.html).
 ### What rights do I have regarding my personal information and how can I exercise these rights?
 Under the law of some jurisdictions, you may have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller. You may be entitled to additional rights based on applicable data privacy laws in your jurisdiction.
 In addition, you can object to the processing of your personal information in some circumstances (such as where we are using the information for direct marketing).
+These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or which we need to defend claims against us. In addition, most web browsers have a "Do Not Track" feature that lets you tell websites you do not want to have your online activities tracked. Currently, there is not an accepted standard on how companies should respond to web browsers' "Do Not Track" signals. Accordingly, our Services and Software do not currently recognize or respond to "Do Not Track" browser signals. However, you can learn more about Adobe's advertising practices and your privacy choices [here](https://www.adobe.com/privacy/opt-out.html).
+These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or which we need to defend claims against us. In addition, Adobe websites recognize the Global Privacy Control available in some web browsers. If your browser is configured to send this signal, Adobe will opt you out of Adobe's use of advertising cookies on that browser. You can learn more about Adobe's [advertising practices](https://www.adobe.com/privacy/marketing.html) and your privacy choices [here](https://www.adobe.com/privacy/opt-out.html).
 To exercise any of these rights (including deactivating your Adobe ID account), you can get in touch with us - or our data protection officer - using the details set out below. Additionally, many of our Services and Software allow you to edit your personal information by accessing the "[my account](https://accounts.adobe.com/)," "my profile," or a similar feature of the service you are using. Likewise, you can delete files or photos you have stored in our Services and Software by logging in and using the deletion functions that are available.
 If you have unresolved concerns, you have the right to report them to your local privacy regulator or data protection authority and, where applicable, you also have the right to lodge a complaint with Adobe Ireland's lead supervisory authority, the Irish Data Protection Commission.
 When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional. For example, to register with Adobe, to create an Adobe ID, and to use some Adobe Services and Software, the provision of some information is mandatory: if relevant information is not provided, then we will not be able to administer an Adobe account to you, or provide you with the Services and Software requested. Other optional information, if not provided, may impact our ability to provide a personalized experience or tailored content or offerings.
 ### What information is collected by companies using Adobe Experience Cloud solutions?
 Adobe Experience Cloud solutions help our business customers personalize and improve the performance of their websites, apps, and marketing messages. For example, these customers may use Adobe Experience Cloud solutions to collect and analyze information about how individuals use their websites ([learn more](https://www.adobe.com/privacy/experience-cloud.html)). The information collected is stored in our services on behalf of and for use by these business customers.
 ### How long does Adobe retain my information?
+When you register for an account and create an Adobe ID, we process and keep most personal information we process on your behalf for as long as you are an active user of our Services and Software. We delete certain personal information we collect about you when we no longer have a business reason to retain it. Additionally, there is some personal information we need to retain even after you close your account to comply with business and legal requirements, such as personal information related to our contract and business transactions with you, which we retain for ten years after your last interaction with us.
+When you register for an account and create an Adobe ID, we process and keep most personal information we process on your behalf have about you for as long as you are an active user of our Services and Software. We delete certain personal information we collect about you when we no longer have a business reason to retain it. When you close your account, we begin deleting certain personal information that we no longer have a business reason to retain, such as your hashed password and your tokenized payment account data. Additionally, there is some we typically retain personal information we need to retain even after you close your account to comply with legal requirements, such as personal information related to our contract and business transactions with you, which we need to retain for ten years after your last interaction with us.
 Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a permanent record of the fact that you have asked us not to send you direct marketing or to process your information so that we can respect your request in the future.
+### Can children use Adobe Services and Software?
+### Can children use Adobe websites and apps?
 Adobe Services and Software are not intended for minors under the age of 13, except in limited situations where certain Creative and Document Cloud applications may be available to children for educational purposes under the direct supervision of a teacher or parent.
 For more information about the collection and use of this and other student data (for students over the age of 13) please see the [Adobe & Student Privacy page](https://www.adobe.com/privacy/student-policy.html) for more details.
 Additionally, Adobe makes available a [Privacy for Younger Users](https://www.adobe.com/privacy/policy_youngerusers.html) page to provide information for younger users of Adobe's Services and Software (who are over 13 years of age) in an age appropriate format.
 ### Who can I contact with questions or concerns?
 If you have a privacy question, concern, or request, please fill out a [privacy inquiry form](http://www.adobe.com/go/privacyinquiry).
 If you are outside North America, you can also get in touch with Adobe Ireland's data protection officer at [DPO@Adobe.com](mailto:DPO@Adobe.com) or by postal mail at 4-6 Riverwalk, Citywest Business Park, Dublin 24, Ireland.
+**Adobe Data Protection Office
+**Email: [DPO@adobe.com](mailto:%20DPO@adobe.com)
 For Marketo specific privacy questions, concerns, or requests please contact us by email at [privacyofficer@marketo.com](mailto:privacyofficer@marketo.com).
 For Magento specific privacy questions, concerns, or requests please contact us by email at [privacy@magento.com](mailto:privacy@magento.com).
 For Workfront specific privacy questions, concerns, or requests please contact us by email at [privacy@workfront.com](mailto:privacy@workfront.com).
 For Allegorithmic specific privacy questions, concerns or requests please contact us by email at [privacy@allegorithmic.com](mailto:privacy@allegorithmic.com).
+For practices that are covered by our [GDPR Validation](https://www.adobe.com/content/dam/cc/en/security/pdfs/gdpr_privacy_practices_validation_letter.pdf) or [PR](http://privacy.truste.com/privacy-seal/validation)[P Certification](http://privacy.truste.com/privacy-seal/validation), please note that if you have an **_unresolved_** privacy or data use concern that we have not addressed satisfactorily within 30 days, you may also reach out to our U.S.-based third party dispute resolution (free of charge) at [http](https://feedback-form.truste.com/watchdog/request)[s://feedback-form.truste.com/watchdog/request](https://feedback-form.truste.com/watchdog/request).
+For practices that are covered by our [PR](http://privacy.truste.com/privacy-seal/validation)[P Certification](http://privacy.truste.com/privacy-seal/validation), if you have an **_unresolved_** privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at [http](https://feedback-form.truste.com/watchdog/request)[s://feedback-form.truste.com/watchdog/request](https://feedback-form.truste.com/watchdog/request).