Effective: September 15, 2020
INTRODUCTION & SCOPE
DATA WE COLLECT
If you are registered for the Unity Insider Program, the following information is collected by us about you:
Active Collection from You
Country of Residence
Other Contact/Account Information
Personal Details to fulfill any contract we may enter with you, such as payment information
Passive Collection from You
Our partner, CreatorIQ, collects certain information about you in their platform related to your likely influence in social media. To the extent you permit access by CreatorIQ to your social media details, we may collect the following information:
The number of followers you have on social media
The number of views of any content you create and the duration of views on social media
The number of shares of your content on social media
The monetized playback
Gross revenues earned through advertising clicks
The number of times your videos are added to playlists
The number of subscribers gained and lost on your channel
The number of “likes, replies, and tweets”
The number of links and Twitter cards have been clicked; and,
Estimated gross Cost per mille
HOW WE USE & DISCLOSE YOUR DATA
Unity will use the information we collect for the following purposes:
Assessing adoption of Unity products and services and other business intelligence information as described in this Policy
Determining when to enter a specific contractual relationship and appropriate remuneration with a specific Unity Insider (note- participation in the program does not guarantee any payment or award from Unity absent a written agreement for content creation)
Assessing feedback for improvements and suggestions related to Unity products and services
Auditing to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
Preventing fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
Developing new products and services;
Enhancing, improving, or modifying our current products and services and/or assisting our developers with this activity;
Identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
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;
You can consult the list and location of our affiliates here: https://unity3d.com/contact/addresses
Other Potential Uses and Disclosures of Your Data Include:
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- 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.
EU DATA AND SPECIFIC LEGAL BASIS OF DATA PROCESSING
We collect your data with your consent and use your data with your consent, pursuant to fulfilling a contract with you,if applicable, or in our legitimate interests.
We maintain certain data about you and content you create after you terminate your participation in the Unity Insider Program when our legitimate interests outweigh your privacy rights including as described below:
We may maintain your account information and other data collected as described in this policy for as long as you have an account, or as long as we have a contractual obligation to you, if applicable. Additionally, certain financial data is subject to be maintained for longer periods in order for us to comply with legal obligations, including but not limited to satisfying taxing authority audits, maintaining our books and records for reporting to our investors, or to comply with any valid legal process. We may maintain content created by you for the period described in any agreement we may have with you.
Please note that to the extent any insights generated from your data or provided by response to your content have been aggregated and anonymized, we may keep this information.
If you have any concerns about Unity’s processing of your data, or about how to exercise your rights, please contact firstname.lastname@example.org. Please note that you may lodge a complaint with your Data Protection Authority; however, we would appreciate the opportunity to address your complaint directly first.
HOW WE SHARE YOUR DATA
We may share information with with the following parties for the purposes described herein:
Safety, security, and legal compliance: We may share your information:
When we have a good faith belief that we are required to disclose the information in response to legal process (e.g., if we receive a court order, search warrant, subpoena, or similar legal process);
To satisfy any applicable laws or regulations:
If we believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
When we have a good faith belief that there is a meaningful risk that poses a threat to the safety of you, another person or the public generally; and
In order to protect the rights or property of Unity, including to enforce the terms and licenses that govern the use of the Services.
Sale or merger: In the event that Unity explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets, we may share or transfer all of your information, including personal information.
De-identified and/or aggregated information: Some of the information we collect does not directly identify you or your device. We may modify other information that can identify you to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information with any third party without restriction and use it for any purpose.
EXERCISING YOUR RIGHTS TO ACCESS, CORRECT, AND DELETE YOUR DATA
In order to access, correct or delete your data with the Unity Insider Program, you must write to email@example.com and make your request. You may also write to firstname.lastname@example.org, and we will forward your request to CreatorIQ. Should you experience any difficulties in accessing, correcting or deleting your data, please report such incidents directly to email@example.com.
DATA TRANSFERS OUT OF COUNTRY OF ORIGIN
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.
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.
POLICY ON CHILDREN’S DATA
Our Platform is intended for general audiences. Unity does not knowingly collect any personal information from children. If any party becomes aware that a child under the age of 13, or under the age of 16 for those parties in the European Economic Area, has provided us with personal information in contravention of our policies, they should contact us at DPO@unity3d.com.
Some third parties, such as platform providers like the iTunes Store or Google Play, may provide age-based ratings on some of the apps created by Developers. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.
CHOICES YOU HAVE ABOUT THE USE OF YOUR DATA
SAFEGUARDING YOUR DATA
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.
CALIFORNIA NOTICE OF RIGHTS
This notice is designed to explain how California residents may exercise their privacy rights under the California Consumer Privacy Act. This notice is incorporated into this policy. Generally, under this new law, California residents have:
- A right to transparent notice about the collection of your data;
- 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,
- A right to request deletion of personal information in certain circumstances;
- A right to opt-out of sales of personal information (note participating in the Insider Program does not involve selling of information);
- An ability to appoint a third party representative to assist you with exercising your rights and,
- 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.
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. For third party representatives writing in on behalf of Unity Insider Program 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.
Sharing with third parties for direct marketing purposes: 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 DPO@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.
LINKS TO OTHER SITES
To the extent the CreatorIQ Unity Insider Platform may contain links to other sites, applications, and services, you may click on links that take you to other sites, applications, and services. Because Unity does not operate those other sites, applications, and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices. As a reminder, this policy describes Unity’s practices with respect to the Unity Insider Program.
We reserve the right to change our practices and this policy at any time. We may also send an email or provide notice within some or all of our offerings when this policy changes. We encourage you to check this page regularly so that you know what our current practices are.
Unity Technologies, 30 3rd Street, San Francisco, CA 94103 (United States contact)
Unity Technologies ApS, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark (European Union contact)