Adobe Privacy Policy

DATED 2024-06-18 · VERSION 20240701_rev01 · COMPARED WITH 20240301_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20240301_rev01 to 20240701_rev01

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

+Last updated: February 14, 2024
+Last updated: June 18, 2024
 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.
 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 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)"
 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.
 ### Summary of Key Points
+- **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]().**
+At Adobe we take data privacy seriously. We believe in transparency so you can control your data and make informed choices about how it is used. We are here to support and protect your privacy decisions wherever you use our products and services. Adobe prioritizes your control over the data you store in the cloud in the following ways:
 - **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).**
+- This policy also explains when we will first get your consent before processing your personal information, including when doing so is required by law.
 - 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).
 - 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]().
 - 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).
 - 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).
 - 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).
 - 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, 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 Software as well as your content
+- Analysis of your use and navigation of the Services and Software;
+- Analysis of your content subject to your opt-out and consent rights.
 Professional, Education or other demographic information, such as:
 - Profile information (e.g., account profile, public profile, Behance profile).
 Commercial and transaction information, such as:
 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 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**
+**How we process 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.
 **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.
     - Administering product or platform skill/knowledge courses and other content, including testing and certifications (as applicable);
     - 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:
+- As required by Adobe to conduct our business and pursue our legitimate interests:
+    - Analyzing your **content** and its characteristics using automated techniques, in the following circumstances:
+        - **Operational Use**. Our Services and Software will access your content stored locally on your device ("Local Content") and content that you have uploaded to our servers or create using our cloud-based Services ("**Cloud Content**"), to enable the normal running of the Services and Software.
+        - **Content Analytics with Cloud Content**. Subject to your opt-out rights, including those described [here](https://helpx.adobe.com/manage-account/using/machine-learning-faq.html), we may perform analytics with Cloud Content to help us understand how our users are using our Services and Software to allow us to improve your Services and Software experience, provide recommendations to you, and customize your experience. Insights from Content Analytics may be used to inform our marketing to you, subject to your opt-out rights regarding our marketing.
+    - Analyzing your **content** and its characteristics using automated techniques or with human review, in the following circumstances:
+        - **Illegal and Abusive Cloud Content**. Cloud Content may be automatically scanned to ensure we are not hosting illegal or abusive content, like Child Sexual Abuse Material. Human review may occur when your Cloud Content is flagged or reported as illegal or abusive.
+        - **Public and Shared Cloud Content**. All public and shared Cloud Content is subject to review for intellectual property issues and safety issues (for example, violence and nudity). If you choose to share your Cloud Content with others using our Software and Services, we may automatically review this shared Cloud Content to flag abusive behavior (such as spam or phishing). When you make your Cloud Content publicly available, additional human review may occur.
     - 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, 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, 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);
+    - 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:
+        - Detect and prevent fraudulent, deceptive, or, illegal activity, or misuse of our Services and Software (where your consent is not required)
+        - 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));
+    - 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 profile information, your interaction with our communications (excluding your content), to:
+        - Detect and prevent fraudulent, deceptive, or, illegal activity, or misuse of our Services and Software;
+        - Improve our Services and Software, and the user experience, subject to your opt-out and consent rights, including those described here; and
+        - Tailor and customize the Services and Software through marketing communications ([learn more](https://www.adobe.com/privacy/marketing.html))
     - 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;
     - 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.
 If legitimate interest is not an available legal basis in a particular jurisdiction, we will engage in the processing activities described above on a legal basis that is available in that particular jurisdiction.
+- Where required, when you give Adobe your consent or otherwise consistent with your choices:
+- Where required, **when you give Adobe your consent** or otherwise consistent with your choices:
     - 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;
     - Placing cookies and using similar technologies in our Services and Software and in email communications, in accordance with our [Cookies Policy](https://www.adobe.com/privacy/cookies.html) and the information provided to you when those technologies are used;
+    - 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;
+    - Accessing information stored on your device for the following operational uses:
+        - Information relating to your use of, and engagement with, Services and Software related to crash reports in order to fix the underlying problem causing the crash;
+        - Information which you allow us to receive through device-based settings (e.g., photos, location and camera) in order to provide certain functionality within our Services and Software;
+    - Accessing information stored on your device which you allow us to receive through device-based settings (e.g., photos, location and camera) in order to provide certain functionality within our Services and Software;
+    - Analyzing your use and navigation of the Services and Software or your content and its characteristics using automated techniques or human review in order to:
+    - Analyzing your use and navigation of the Services and Software or your content (including metadata about your content) using techniques such as machine learning in order to detect and prevent fraudulent, deceptive, or illegal activity or misuse of the Services and Software, and improve our services and the user experience; and
+        - Detect and prevent fraudulent, deceptive, or illegal activity or misuse of the Services and Software;
+        - Improve our services and the user experience, such as through the Adobe Product Improvement Program as described [here](https://www.adobe.com/privacy/apip.html); and
+        - Respond to your request (e.g., customer service).
     - Allowing you to participate in sweepstakes, contests, and similar promotions and to administer these activities.
 On 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.
 - For legal reasons:
     - Responding to requests by government or law enforcement authorities conducting an investigation.