Dolby Laboratories, Inc. (“Dolby”, “we” or “us”) respects your concerns about privacy. This Dolby Privacy Policy for the Dolby Personalization App (“Personalization App Privacy Policy”) applies to the information that we collect when you use the Dolby Personalization App (the “App”). Dolby is a controller, responsible person or equivalent term used under applicable law with regards to your personal information.
The App is designed to enable you to create an audio filter (referred to as a “PHRTF”) that is tailored to your personal characteristics for use with headphones and other products equipped with Dolby Atmos audio presentation technology. This Personalization App Privacy Policy does not apply to any website, mobile app or product operated by Dolby that has a separate privacy policy. Please see the Dolby Global Privacy Policy for information about Dolby’s privacy practices for the services referenced there.
This Policy describes the types of personal information we obtain when you use the App, how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The Policy also describes the measures we take to safeguard the personal information we process, how long we retain it and how you can exercise your rights and contact us about our privacy practices. This Policy does not apply to information that does not identify you, such as the PHRTF itself and information that has been aggregated with other records.
This Policy may be updated periodically to reflect changes in our privacy practices. We will indicate at the top of the Policy when it was most recently updated.
Information We Obtain
We may obtain certain information in connection with your use of the App.
Information You Submit
We collect the information that you submit or provide us, including:
- We collect identifiers and contact information, such as your name and email address and other information you provide when you sign up for the App (“Account Information”).
- To personalize the audio setting (i.e., create the PHRTF), we will ask you to capture a series of images of your head (“Capture Images”). We do not use this information to uniquely identify you. To help us generate the PHRTF, we also ask you to complete an optional survey including your birth sex and age.
- If you contact us directly or respond to feedback surveys, we may receive additional information about you. For example, if you use our customer support tools or services, we may obtain any other information you choose to provide.
Data Collected by Automated Means
When you access the App, we may obtain certain information by automated means. The information we obtain in this manner may include information about how you interact with the App, the date and time you access the App, the device technology you are using, and your interactions with and preferences on our App. We may automatically obtain analytics information relating to products you purchase from us, such as usage statistics, the type of devices you connect to your product, dates and times of app visits, and technical information about your product.
We also use automatically collected information using the device camera and the TrueDepth API provided by Apple (such information, “TrueDepth Data”), together with your Capture Images, to create your PHRTF. None of the TrueDepth Data is persistently stored on your device, nor will it be transferred off of your device to Dolby, unless you opt-in to such transfer.
We also may obtain other information about you, in ways that we describe at the time of collection or otherwise with your consent.
How We Use the Information We Obtain
We may use the information we obtain about you to:
- Provide and update our products and services;
- Personalize your experience with our products and services, including Atmos products;
- Establish and manage your account;
- Communicate about and administer our products, services, events, surveys, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications, and by providing customer support);
- Track and understand how you use and interact with our products and services;
- Perform analytics, and to improve and develop new products and services;
- Increase and maintain the safety and security of our products and services and prevent misuse;
- Protect against, identify and prevent fraud, physical or other harm, financial loss and other (suspected or actual) criminal or otherwise illegal activity, claims and other liabilities, and to establish, exercise or defend our legal rights; and
- Comply with and enforce applicable legal requirements or legal process (such as a court order or subpoena), requests by government agencies (such as law enforcement authorities), relevant industry standards, and policies, including this Policy.
As required by applicable law, we use the personal information we obtain about you to comply with relevant legal requirements, carry out our contractual obligations and, as permitted by law, pursue our legitimate interests (such as managing the App and operating, evaluating and improving our business), or we obtain consent to process personal information. We also may use personal information in other ways for which we provide specific notice at the time of collection. You are not required to provide to Dolby any of the personal information described above but, if you choose not to do so, you may not be able to use the App.
For information about the legal bases under the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”), the UK General Data Protection Regulation, the Brazilian General Data Protection Law and other comparable laws that require a legal basis for data processing, please refer to Appendix I.
Third-Party Analytics
We may use third-party web analytics tools on our App, such as Google Analytics, Facebook, DoubleClick, Sproutsocial, Twitter, and YouTube. The vendors that administer these tools use automated technologies to collect data (such as identifiers associated with your device) to evaluate use of our App. To learn more about Google Analytics, and how to opt out, please visit http://www.google.com/policies/privacy/partners/, or any other URL that Google may provide from time to time.
Information Sharing
We do not sell or otherwise share personal information about you except as described in this Policy.
We may share your personal information with (1) our affiliates and subsidiaries, (2) business partners whose services we use, and (3) our service providers who perform services on our behalf, such as order fulfilment and data storage. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose information about you to others, including public authorities, (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
Data Transfers
We will transfer the personal information we obtain about you to the United States, which may have different data protection laws than the country in which you initially provided the information. However, by default, Capture Images and TrueDepth Data are not transferred off of your device, though you may choose to allow such transfer for customer support or other purposes. To the extent required by applicable law, when we transfer your personal information to recipients in the U.S., we will take appropriate measures to protect that information. For example, if you are located in the European Economic Area (“EEA”), UK, Switzerland or another country that has adopted standard transfer contracts or adequacy decisions, we may enter into those transfer contracts or, if necessary, certify under those adequacy decisions granted to countries to which we transfer personal information, and, where required, put in place additional safeguards to protect your personal information. If you are located in a country that requires consent for international transfers, we will obtain your consent before transferring your personal information.
If you are located outside the U.S., by submitting personal information to us, you understand that this information will be transferred to Dolby in the U.S. If you do not want your personal information transferred to the U.S., please do not submit any information to us.
Your Rights and Choices
We offer you certain choices in connection with the personal information we obtain about you.
To update your preferences, correct your information, limit the communications you receive from us, or submit a request, please contact us as specified in the How to Contact Us section of this Policy.
As required by law, you may have the right to (1) request access to (and a copy of) certain personal information we maintain about you; (2) request that we update, correct, amend, or erase certain personal information; (3) restrict or oppose our processing of your personal information; (4) port your personal information to a third party; and (5) withdraw your consent.
To help protect your privacy and maintain security, we may take steps to verify your identity before handling your request. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. That is the case, for example, if you are in the EEA, UK, or Brazil.
We currently do not respond to “Do Not Track” signals.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Retention of Personal Information
We retain your Account Information until you delete your account. We also retain your Capture Images and TrueDepth Data until the earliest of (a) two years from the date of capture, (b) you change your privacy setting to stop sharing your data with Dolby, or (c) you delete your account.
We recognize the importance of providing you choices about our retention of copies of your video and derived measurements of your features. With your permission, we retain this information for two years so that we can improve the recommended PHRTF for you without the need to capture new video and continue to improve the quality of our audio settings. If you extend our permission, we may retain this information for additional two-year periods. Please see the Settings menu within the App to change the permissions you have granted us to retain video images and measurements of your features.
California Consumer Privacy Rights
This section provides additional details about the personal information we collect from California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For details about the personal information we have collected over the last 12 months, including the categories of sources, please see Information We Collect. We collect this information for the purposes described in How We Use the Information We Obtain. We share this information with the categories of third parties described in Information Sharing. Dolby does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.
Subject to applicable law, you have certain choices regarding your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
- Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
To submit a request, please visit https://www.dolby.com/about/support/. Please select Legal Department as the topic when submitting a request.
You may also email us at Privacy@dolby.com.
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. To request this Statement in an alternative format, please contact Privacy@dolby.com.
Children’s Personal Information
We recognize the importance of protecting children's online privacy. The App is intended for a general audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13 or the legal age of majority in your country, if different from 13. If we become aware that we have collected personal information from a child under this age, we will promptly delete the information from our records. If you believe that a child under the age of 13 or the legal age of majority (if different) may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Policy.
How to Contact Us
If you have any questions about this Policy, or if you would like to exercise your rights, please feel free to send us an email at Privacy@dolby.com, navigate to the customer support link on the App, or write to:
Dolby Laboratories, Inc.
Attn: Privacy – Legal
1275 Market Street
San Francisco, CA 94103-1410
USA
You can also delete your account and make changes to your privacy settings directly in the App.
Appendix I
Purposes for Processing Personal Information
Purpose |
Categories of Personal Information |
Legal Basis |
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