Unity Gum Privacy Policy

Last Edit/Review: First Version

Gum is a new augmented reality creation app that lets you build worlds, capture, and share with your friends. Sign up for Gum.

Introduction & Scope

Welcome to the Unity Gum App (herein “App”). This Privacy Policy will provide you, the User, with information about Unity’s (herein “we”, “us”, “our”, or “Unity”) Gum App processing activities with respect to your Personal Information collected through your use of the App. This policy applies to our Gum Users that have downloaded the Gum App.

Please refer to Unity’s main Privacy Policy to further understand our data processing activities with respect to your Unity ID account data and other data collected as a result of your use of Unity’s other Site, Products or Services as well as your rights with respect to those activities.

Personal Information We Collect and its Sources

By downloading and using the Unity Gum App, We collect Personal Information from you two ways:

• Directly from you when you provide it to us.
• Passively when you use the App.

Personal Information that you actively provide, may include:

• Account Information: The Personal Information you submit to create a Gum account may include your name, age or date of birth, telephone number, mobile number, email address, gender, username, Password(s) that Users create to access parts of the Service or profile picture.
• Financial Information: Details of transactions you carry out through the App and information necessary for the fulfillment of your orders. When Users provide payment (e.g. credit card information, billing address, etc.) information to make a purchase, that information is sent to payment processors who assist Unity. Unity's payment systems are not designed to store credit card numbers.
• Social Feed Content: You may also provide assets for publication or display on public areas of the App (collectively, “Social Feed Content”). Your Social Feed Content is posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your Social Feed Content. Therefore, we cannot and do not guarantee that your Social Feed Content will not be viewed by unauthorized persons.
• Your Communications with Us: Users may provide us with information when they participate in community and forum pages on the App.

By downloading and using the Unity Gum App, Unity may passively and automatically collect the below Personal Information from you:

• Usage Information. We collect information about your activity through our App. Information about your usage may include how you share target assets, user actions, day of first session, day of last session or session length.
• Device Information. The App may also collect device information such as the operating system, hardware and software versions, platform, screen size, and CPU/graphics characteristics.
• Location Information. When you use our App we may collect information about your location. IP addresses can be used to learn about the general location (e.g. city, state and country) of the User’s point of access to the App.
• Audio, electronic, visual, and similar information: The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

For more information on other Personal Information that Unity collects through your Unity account, and your use of other Unity Site, Products or Services, please see our main Privacy Policy. For information on cookies, and similar technologies that may collect information through your use of Unity’s Site, Products, Services and the App please see our Cookie Policy.

Purpose of Collecting Personal Information (How we use your Data)

We use the Personal Information we collect through your download and use of the Unity Gum App to provide, administer, operate and improve the Unity Gum App and its related Services (together, “Services”). Specifically, we may use your Personal Information for the below purposes.

• Providing the functionality of the Services and fulfilling your requests, including to:
  • To create, administer and troubleshoot accounts, Services we provide
  • To credit or accept payments;
  • To provide technical support and respond to inquiries;
  • To prevent fraud, enforce the relevant terms of service or licenses, and protect Users;

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, when we have your consent (e.g., when you are requesting for us to respond to you), and/ or when necessary for our legitimate interests (e.g., to respond to inquiries from customers and potential customers, for license enforcement and prevention of software piracy, to inform decisions around service offerings, and for operational improvements).

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing
  • To send you marketing related emails, with information about our services, new products and other news about our company.
  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Allowing you to participate in sweepstakes, contests or other promotions.

We use this information to manage our contractual relationship with you, or in some cases, based on your consent or our legitimate interest.

• Accomplishing our business purposes
  • To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the App;
  • For data analysis and testing, for example, to improve the efficiency of our App;
  • For App maintenance;
  • For reporting and hosting of data;
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
  • For fraud and security purposes, for example, monitoring to detect and prevent cyberattacks or attempts to commit identity theft;
  • For the prevention of criminal activity or harm to users of our Services;
  • For developing new products and services;
  • For enhancing, improving, or modifying our current website(s), products and services and/or assisting our developers with this activity;
  • For identifying usage trends, for example, understanding which parts of our website(s) and Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users or our publisher’s and other advertising customer’s users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users or assisting our developers with this activity within their business so we can focus our and their energies and resources on meeting our users’ interests;

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have your consent or a legitimate interest.

• Analysis of Personal Information for business reporting and providing personalized services.
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our App is used, so we can improve our website(s) and Services.
  • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our website(s) and Services that we believe will be relevant and interesting to you.

We will perform analyses based on our legitimate interest. We will provide personalized services either with your consent or because we have a legitimate interest.

• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

How we might share the information we collect or receive

• To our affiliates for the purposes described in this Privacy Policy.
  • You can consult the list and location of our affiliates here: https://unity3d.com/contact/addresses
  • Unity Technologies, Inc. is the party responsible for the management of the jointly-used Personal Information.
• To our third-party service providers, to facilitate services they provide to us.
  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, mailing, surveys, auditing, and other services
• To third parties, to permit them to send you marketing communications, consistent with your choices.
  • Unity Ads: We may utilize the data collected from the App to place personalized ads in the App and elsewhere. This usage will permit other parties, such as publishers and attribution companies, to learn about the devices that received, viewed or interacted with ads.
  • Third-party products and services: As discussed in our Cookie Policy and elsewhere, we may permit advertisers and their agents to use cookies or related technologies within the Service to store information on or read information from your browser or device so that they can optimize their advertising campaigns, including to frequency cap and deliver targeted ads.
• To third-party sponsors of sweepstakes, contests, and similar promotions.
• By using the Services, you may elect to disclose Personal Information:
  • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
  • Through your social sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy
• To comply with applicable law and regulations.
  • This can include laws outside your country of residence.
• To cooperate with public and government authorities.
  • To respond to a request or to provide information we believe is important
  • These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
  • To enforce our terms and conditions or licenses; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

Accessing/ Updating/ Deleting Your Information

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data. We provide Users with a variety of ways to access and update their information (described below). For those with Gum accounts described below, please send any requests or questions to mobile_creators@unity3d.com .

Retention

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Our Policies Concerning Children

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at dpo@unity3d.com

For more information on our policies concerning the collection of information from children, please see our main Privacy Policy.

Transfers out of Country of Collection

• Unity has implemented and maintains a framework consistent with applicable law for transfers of data outside of the country of collection, including for transfers out of the EEA.
• Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting DPO@unity3d.com.

Safeguards

• We employ a variety of measures to safeguard the collection, transmission, and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Links to Other Sites

• As a reminder, this statement only describes Unity’s practices with regards to the Unity Gum App.
• Please refer to Unity’s main Privacy Policy to understand our data processing activities with respect to your Unity account data, data collected as a result of your use of Unity Gum App, and other data collected as a result of your use of Unity’s Site, Products or Services as well as your rights with respect to those activities.

Changes to This Privacy Statement

• We reserve the right to change our practices and this statement at any time. We may send an email or provide notice within some or all of our offerings when this statement changes. We encourage you to check this page regularly so that you know what our current practices are.

Contact Us

• DPO@unity3d.com
• Unity Technologies, 30 3rd Street, San Francisco, CA 94103 (United States contact)

Privacy Rights

Information for California Users:

If you are a California citizen pursuant to the "California Consumer Privacy Act of 2018" CCPA, we provide the following details regarding the categories of Personal Information we may have collected within the preceding twelve (12) months:

• Identifiers, such as name, signature, contact information, online identifiers,
• Personal information, as defined in the California customer records law, such as name, contact information, payment card number, credit card number, debit card number, or any other financial information
• Commercial information, such as transaction information and purchase history;
• Geolocation data, such as device location and IP location;
• Audio, electronic, visual, and similar information, such as call and video recordings;
• Device Information, such as the operating system, hardware and software versions, platform, screen size, and CPU/graphics characteristics.
• Inferences drawn from any of the Personal Information listed above to create a [profile/summary] about, for example, an individual's preferences and characteristics.

Source of the Personal Information Collected

Unity collects personal information directly from you as a Gum User as well as your personal information listed above may be collected from you automatically by Unity from the device you're using to access the App.

Unity primarily uses the personal information collected to provide, administer, operate and improve our services. We may use your information for the following purposes:

• Provide our services to you;
• Offer technical support and respond to your inquiries;
• Personalization;
• Process payments;
• Marketing and promotions;
• Analytics and improvement;
• Prevent fraud, enforce the relevant terms of service or licenses, and protect users;
• Identify and suggest connections with other users;
• Create and share statistics and reports regarding aggregate usage of the App;
• Enable user-to-user communications;
• Link to or combine with other information we have gathered;
• Deliver and target advertising, including personalized ads;
• Conduct business intelligence research and analytics; and
• Comply with legal obligations: As we believe it is necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.​

Where Unity Shares the Personal Information it Collects (Categories of Third Parties to whom Personal Information is Disclosed)

Unity only discloses your personal information for the purposes described above with certain third parties, including:

• Unity Affiliates and Subsidiaries
• Third-party Service Providers

Do Not Sell My Information: Unity Gum App does not sell Personal Information for the purposes of the CCPA.

California Rights and Requests

California residents have the right to request the identity of any third parties to whom the resident’s personal information was shared, if such sharing was to enable the third party’s direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to mobile_creators@unity3d.com OR to opt-out of having your personal information shared with third parties for their direct marketing purposes, please email us at DPO@unity3d.com.

A right to transparent notice about the collection of your data;

1. A right to transparent notice about the collection of your data;
2. A right to know what personal information Unity holds about you, including where we obtain it and the categories of third parties with whom we share it,
3. A right to request deletion of personal information in certain circumstances;
4. A right to opt-out of sales of personal information;
5. An ability to appoint a third party representative to assist you with exercising your rights and,
6. A right not to be discriminated against for exercising your rights.

• Please note Unity does not discriminate in its provision of services to you based on exercising your rights.
• Your requests to delete data is limited to data that Unity is not allowed to retain under the CCPA. Unity may retain data for certain purposes, including completing transactions for you or reasonably related to completing transactions for you, detecting security incidents, illegal activity and fraud, maintaining our systems, complying with applicable law and legal obligations, engaging in public or peer reviewed research provided we comply with applicable ethics and privacy laws related to such research, or enabling solely internal purposes such as financial recordkeeping.
• To exercise your rights under the CCPA, please click here or email mobile_creators@unity3d.com.
• You may ask a third party representative to assist you in exercising your rights. Third parties may write to DPO@unity3d.com to provide documentation of their right to act on your behalf. Unity Gum account holders may also send data reports obtained through your account directly to your representative. You need only to provide their email or mailing address instead of your own when ordering. For third party representatives writing in on behalf of Unity Gum account holders, please provide the name and any signed documentation you may have to act on behalf of the account holder, or you may ask the account holder to write to us from their account email to provide us permission to transact with you directly. Unity reserves the right to take reasonable steps to verify the authenticity of identities and authorizations in compliance with applicable laws prior to making any disclosures.
• More information on your rights as a Californian and instructions on how to exercise them with Unity may be found here.
• You may view our CCPA Transparency Report at /legal/privacy-report. This report provides details on our responses to requests to access, delete or opt-out under CCPA.

• How we respond to “Do Not Track” signals: We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information in our Cookie Policy about how to prevent the delivery of targeted ads, and information in this policy about how to prevent Google Analytics and Twitter from collecting information. We do not, however, recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.

Europe Privacy Rights

If you are a European Union resident, the General Data Protection Regulation provides certain rights to you with respect to your personal data. Where Unity is a data controller, you have the following rights:

• Right to Access - You have the right to request Unity provide you with a copy of your personal data.
• Right to Rectification (Correction) - You have the right to request Unity to correct any information about you that you believe is incorrect. You also have the right to request Unity to complete information about you that you believe is incorrect.
• Right to Erasure (Deletion) - You have the right to request Unity to erase your personal data, under certain conditions.
• Right to Restrict Processing - You have the right to request Unity to restrict the processing of your personal data, under certain conditions.
• Right to Object to Processing - You have the right to object to Unity’s processing of your personal data, under certain conditions.
• Right to Data Portability - You have the right to request Unity to transfer your personal data that we have collected to another organization, or directly to you, under certain conditions.

In addition, where our processing activities in respect of your Personal Data are subject to the GDPR, you may lodge a complaint with a European Union supervisory authority. If you do have a complaint, we would appreciate the chance to deal with your concerns before approaching your supervisory body, so please contact us at dpo@unity3d.com if you wish to discuss any complaint. You can find your supervisory authority here.

Canada Privacy Rights

The Canadian Personal Information Protection and Electronic Documents Act provides certain rights with respect to your personal data, such as:

• Right to Access - You have the right to request Unity provide you with a copy of your personal data.
• Right to Rectification (Correction) - You have the right to request Unity to correct any information about you that you believe is incorrect. You also have the right to request Unity to complete information about you that you believe is incorrect.

Brazil Privacy Rights

The Brazilian General Data Protection Act provides you the right to:

• Confirm Unity's processing of your data;
• Access your data;
• Correct your incomplete, inaccurate, or outdated data;
• Request anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the Brazilian General Data Protection Act;
• Port your data to other service providers or suppliers of products;
• Delete your personal data when processed with your consent;
• Obtain information on the public and private entities with whom Unity shared your data;
• Obtain information on the possibility of not providing consent and on the consequences of the denial;
• Revoke your consent to the processing of your data when we seek your consent; and
• Lodge complaints before data protection authorities.

Israel Privacy Rights

The Israel Protection of Privacy Law 5741-1981: Any information provided by you is on a voluntary basis with no legal requirement to do so, but if you refuse to provide such information we may not be able to provide you with the Services. According to the Protection of Privacy Law, each person is entitled to inspect, either himself or through a representative authorized by him in writing or his guardian, any information about him kept in a database.

To exercise the above rights, email DPO@unity3d.com.