Adobe Privacy Policy

20231001_rev01 · COMPARED WITH 20230701_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE

Full text changes — 20230701_rev01 to 20231001_rev01

1Last updated: April 20, 2023
1Last updated: September 13, 2023
22
33The 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.
44
55If 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.
66
77If 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.
88
9Please 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)"
9Please 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 and providers 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)"
1010
1111If 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.
1212
1313### Summary of Key Points
1414
15- **Where your consent is required, we will obtain your permission before (i) sending you news and promotional material about Adobe; (ii) accessing information stored on your device relating to your use of, and engagement with, Services and Software (e.g. Adobe Connect meetings) and crash reports; and (iii) analyzing your content. You can withdraw your consent to such activities at any time. [Learn more]().**
15- **Where your consent is required, we will obtain your permission before (i) sending you news and promotional material about Adobe; (ii) accessing information stored on your device relating to your use of, and engagement with, Services and Software (e.g., Adobe Connect meetings) and crash reports; and (iii) analyzing your content. You can withdraw your consent to such activities at any time. [Learn more]().**
1616- **This policy explains when we process personal information for our legitimate interests. You can ask us to stop processing this information. [Learn more about your rights and how you can exercise them](https://www.adobe.com/privacy/policy.html).**
1717- We use your personal information to enable you to register with Adobe and to provide you with our Services and Software, and other products or services that you request. [Learn more](https://www.adobe.com/privacy/policy.html).
1818- We provide interactive features that engage with social media sites, such as Facebook. If you use these features, these sites will send us personal information about you. [Learn more]().
1919- We use cookies and other technologies to track the use of our Services and Software. To learn about opportunities to choose not to allow cookies, click [here](https://www.adobe.com/privacy/opt-out.html). If you are using our website in a browser, this information is also available in our [Cookies Policy](https://www.adobe.com/privacy/cookies.html).
2020- There are several places within Adobe's Services and Software that allow you to post comments, upload pictures, or submit content which will be publicly available where you choose to participate in these activities. We also disclose personal information to other companies in the Adobe family and with advertising and sales partners consistent with your choices. We also disclose information with third parties we engage to process personal information on our behalf or when such sharing is required by law, or in certain other situations. [Learn more](https://www.adobe.com/privacy/policy.html).
2121- We transfer your personal information to the US and other countries, which may be outside the country in which you live. We use government-approved contractual clauses such as European Commission approved Standard Contractual Clauses to help protect your personal information. [Learn more](https://www.adobe.com/privacy/policy.html).
4444- Name;
4545
4646- Email address;
4747- Telephone number;
4848- Postal or Physical Address;
4949- Country;
50- Account Password.
5150
5251Commercial and transaction information, such as:
5352
5453- Payment/billing information (where an app or website is 'paid for');
5554- Licenses purchased;
5655- Eligibility information (e.g., student or teacher identification for student and teacher editions of apps);
57- 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);
56- Content of and information provided through customer support and other communications (e.g., recorded customer and technical support calls and stored content of your correspondence with us via our website, chat features, phone and video calls, emails, and other channels);
57
5858- Types of Services and Software of interest.
5959
6060Professional, education or other demographic information, such as:
6161
6262- Date of birth;
6363- Company or school name;
9595Professional, Education or other demographic information, such as:
9696
9797- Profile information (e.g., account profile, public profile, Behance profile).
9898
9999Commercial and transaction information, such as:
100100
101- 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.
101- Content that includes personal information which is sent or received using an online feature of Adobe Services and Software, or which is stored on Adobe servers, such as documents, photos, videos, activity logs, direct feedback from you, metadata about your content, user generated requests such as search terms, prompts (e.g., text, images, videos, audio, etc.), inquiries, feedback, and other information you may disclose when you access or use our Services and Software as well as any information the Services and Software returns in response to such requests.
102102
103103Sensitive personal information, such as:
104104
105105- 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.
106106
107107The following links provide further information on:
176176 - Sending you necessary communications (for example, related to payments or expiration of your subscription); and
177177 - Providing customer service or support.
178178- As required by Adobe to conduct our business and pursue our legitimate interests, in particular:
179179 - Providing you with the Adobe Services and Software for which you have registered and any other products and services you have requested;
180180 - 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;
181181 - 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);
182 - 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);
183 - 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);
184
182 - Analyzing your use and navigation of our Services and Software, your content, your profile information, and your interaction with our communications, through both automated (e.g., machine learning) and manual methods to tailor, customize, and improve the Services and Software, and marketing communications ([learn more](https://www.adobe.com/privacy/marketing.html)) (where your consent is not required);
183 - Analyzing your use and navigation of our Services and Software, as well as your content and metadata about your content through both automated (e.g., machine learning) and manual methods to:
184 - Detect and prevent fraudulent, deceptive, or, illegal activity, or misuse of our Services and Software (where your consent is not required)
185 - Improve our Services and Software, and the user experience (where your consent is not required, and subject to settings we may provide you, including those described [here](https://helpx.adobe.com/manage-account/using/machine-learning-faq.html));
185186 - Diagnosing problems in our Services and Software;
187
186188 - 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;
187189 - 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);
188190 - Investigating and responding to any comments or complaints that you may send us;
189191 - 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);
190192 - Sharing account information registered under a business email address with employers for account migration purposes;
191193 - 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;
210212
211213On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time. Where we rely on consent to process information, you can withdraw your consent to such activities at any time.
212214
213215- For legal reasons:
214216 - Responding to requests by government or law enforcement authorities conducting an investigation.
215217
216 - Using or disclosing information as reasonably necessary to detect, prevent, or otherwise address fraud, security, potential deceptive or illegal activities, misuse of Services and Software or technical issues and software piracy (e.g., to confirm that software is genuine and properly licensed), helping to protect you as well as Adobe.
218 - Using or disclosing information as reasonably necessary to detect, prevent, or otherwise address fraud, security, potential deceptive or illegal activities, misuse of Services and Software, or technical issues and software piracy (e.g., to confirm that software is genuine and properly licensed), helping to protect you as well as Adobe.
217219
218220Where this processing and these disclosures are not strictly required by law, Adobe may rely on its legitimate interests, where available, and those of third parties described above.
219221
220222### Does Adobe disclose my personal information to others?
221223
222224**Disclosing to other Data Controllers**
223225
224226We 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)).
225227
226We 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.
228We 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).
227229
230Third-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.
231
228232**Disclosing for Fraud Prevention, Safety and Security Purposes**
229233
230234We 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.
231235
232236Additionally, 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.
233237
234238**Disclosing to Data Processors**
235239
236We 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.
240We 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 (including those that may record or store communications) include providers of customer support services, chatbots, session replay partners who provide services which recreate a web or app session showing meaningful insight into a visitor's experience, providers of analytics technologies that record and analyze your interaction with our websites to help us improve your experience, providers of artificial intelligence technologies that record and analyze your content or communications, 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.
237241
238242**Other Information Disclosure**
239243
240244Adobe may also disclose your personal information:
241245
242246- When you agree to the disclosure;
258262### Where does Adobe store my personal information?
259263
260264Your personal information and files are stored on Adobe's servers and the servers of companies we engage to provide services to us.
261265
262266### Does Adobe transfer my personal information across national borders?
263267
264The 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.
268The main locations where we process your personal information are the US and India, but we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. 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.
265269
266270If 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).
267271
272Adobe complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Adobe has also certified to the US Department of Commerce that it adheres to EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Adobe has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. Adobe's commitments under the Data Privacy Framework are subject to the investigatory and enforcement powers of the United States Federal Trade Commission. To learn more about the Data Privacy Framework program, and to view our certification, please visit [https://www.dataprivacyframework.gov/s/](https://www.dataprivacyframework.gov/s/).
273
268274The 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).
269275
270276### What rights do I have regarding my personal information and how can I exercise these rights?
271277
272Under 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.
278When provided for by applicable law, you 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.
273279
274280In 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).
275281
276282These 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).
277283
278284To 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.
301307### What information is collected by companies using Adobe Experience Cloud solutions?
302308
303309Adobe 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.
304310
305311### How long does Adobe retain my information?
306312
307When 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.
313When 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.
308314
309315Where 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.
310316
311317### Can children use Adobe websites and apps?
312318
313319Adobe 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.
325331### Who can I contact with questions or concerns?
326332
327333If you have a privacy question, concern, or request, please fill out a [privacy inquiry form](http://www.adobe.com/go/privacyinquiry).
328334
329335If 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.
330336
331**Adobe Data Protection Office
332**Email: [DPO@adobe.com](mailto:%20DPO@adobe.com)
337For practices that are covered by our [PRP 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 [https://feedback-form.truste.com/watchdog/request](https://feedback-form.truste.com/watchdog/request).
333338
334For Marketo specific privacy questions, concerns, or requests please contact us by email at [privacyofficer@marketo.com](mailto:privacyofficer@marketo.com).
335
336For Magento specific privacy questions, concerns, or requests please contact us by email at [privacy@magento.com](mailto:privacy@magento.com).
337
338For Workfront specific privacy questions, concerns, or requests please contact us by email at [privacy@workfront.com](mailto:privacy@workfront.com).
339
340For Allegorithmic specific privacy questions, concerns or requests please contact us by email at [privacy@allegorithmic.com](mailto:privacy@allegorithmic.com).
341
342For 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).
339If you believe Adobe maintains your personal data in one of the services within the scope of our Data Privacy Framework certification, you may direct any inquiries or complaints concerning our Data Privacy Framework compliance by filling in our privacy inquiry form. 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 [https://www.ana.net/content/show/id/accountability-dpf-consumers](https://www.ana.net/content/show/id/accountability-dpf-consumers). If neither Adobe nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Data Privacy Framework Panel. For more information on this option, please see Annex I of the EU-U.S. Data Privacy Framework Principles.