NOTICE TO CALIFORNIA RESIDENTS REGARDING CALIFORNIA CONSUMER PRIVACY ACT EFFECTIVE JANUARY 2020
Does Unity actually "sell" personal information?
Unity does not, and will not, provide your personal information in direct exchange for money. Therefore, in the literal sense, Unity does not sell your data. However, the CCPA requires Unity to disclose if it sells personal information and under the CCPA’s expansive definition of “sell”, the following activities may constitute a CCPA sale of data.
Many games include advertisements. When you play a game that utilizes Unity’s Ad Network, the device you are using sends an advertising identifier (called an “Ad ID”) to Unity. Under the CCPA, this Ad ID is considered personal information. Why? Because it may include information on you such as your location, the device you are using, some of the activities you’ve completed in your game and more. We have included the full list of “personal information” below for your convenience.
Unity shares the Ad ID with our advertising and publishing partners and sometimes our partners may use this Ad ID to look up information about you. This may include things like your online activities, purchases you’ve made or websites you’ve visited. This is all done to personalize future advertisements you may see. In fact, the whole point is to give the advertiser an opportunity to advertise to you - and specifically to you - with a personalized ad. For this reason, under CCPA, sharing the Ad ID may be a sale of personal data.
If you do not see these options, your developer has enabled privacy controls to create a more privacy-protective experience or to indicate that this app is directed to children under the age of 13. As a result, we deliver ads to you based only on contextual data (e.g., the game you are playing).
If you are playing a game that uses Unity Analytics enabled, then, yes, Unity is collecting personal information on you. While this is controlled on the publisher side, you do have the ability to opt out of data collection. Please note that Unity does not believe the usage of analytics by your developer is a “sale” of personal information; however, we have offered the opt-out opportunity to this service. To access your privacy settings, look for your privacy information and account services (each location will be different in each game) and if you have trouble finding it, contact the games provider. Once you begin to exercise your privacy rights, you will, however, be pushed into the new Unity web flow that will guide you through the process.
Ok, if I'm a game player, under CCPA, what rights do I have?
As a game player, you have the right to opt out from personalized ads, request the deletion of certain personal information, and/or request a data disclosure of your personal information from Unity. In general, Unity does not have enough information about you as an individual to locate your records or verify your identity through an email or mailed request. Therefore, we have created an alternative way for you to authenticate yourself for a CCPA data disclosure when you are inside of a game. You may also exercise your opt-out inside an app without going through the formal verification.
Please note if you do not see opt-out options in your app, your game developer has enabled privacy controls to create a more privacy-protective experience or to indicate that the app is directed to children under the age of 13. When this is done, we deliver ads to you based on contextual data (e.g., the game you are playing) instead of your personal information.
What does this look like?
To exercise your rights under CCPA, you can start by clicking on the privacy settings banner or at anytime by clicking on the privacy icon in the left bottom corner of a Unity ad. The icon looks like this:
Once you click on this icon, you will be guided through a series of steps to achieve the changes or requests you prefer.
You can opt-out of personalized ads inside of the game you are playing, or, if you provide your preferred email and go through verification inside the ad, you can get a link to order a data disclosure report or opt-out of personalized ads for the game you are playing at that time. We will not use your email for any purpose other than helping you exercise your privacy rights.
What if I am a Unity developer, what rights do I have?
As a Unity developer, you have a right to request the deletion of certain personal information, and/or request a disclosure of personal information from Unity. You may do this in the privacy settings of your account. Please note Unity cannot delete certain personal information it uses for business purposes, including billing and payment records, license verification, fraud prevention information, and data to assure security and integrity of our systems. We do not share developer account information in any way that constitutes a “sale” of data under California law; however, we permit you to opt-out of certain uses of your personal information, such as contributing information to certain internal usage statistics analysis.
How do I exercise my rights?
If you are a Unity developer, please log in to your account and view your privacy settings page to obtain data disclosures and adjust your privacy settings
I am just visiting the Unity website. What rights do I have?
The processes for exercising your rights described in this notice should appear in the apps you use containing Unity services and on our website. Contact DPO@unity3d.com if you have any questions.
SUMMARY OF UNITY’S PERSONAL INFORMATION COLLECTION AND USE PRACTICES
Categories of Personal Information Collected
Depending on the type of interaction you have with Unity, Unity may collect information in some or all of the categories of personal information listed below:
- Identifiers, such as name, signature, contact information, online identifiers, and government-issued ID numbers;
- Personal information, as defined in the California customer records law, such as name, contact information, payment card number, medical information, insurance information, education information, employment information, and government-issued ID numbers;
- Characteristics of proteced classifications under California or federal law, such as sex, age, race, disability, and marital status;
- Commercial information, such as transaction information and purchase history;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location and IP loacation;
- Audio, electronic, visual, and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information; and
- 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 Unity user as well as from sources from the categories of sources listed below:
- Third-Party Social Networks
- Unity Partners
Your personal information listed above may be collected from you automatically by Unity from the device you're using to access and play games developed using Unity software or services.
How Unity Uses the Personal Information it Collects (Intended Use Purposes)
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;
- 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;
- Permit game players wishing to play connected games to be matched with other players via Multiplay or other connected games services;
- Create and share statistics and reports regarding aggregate usage of Unity-powered apps;
- 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.
Right to Delete Personal Information
All of the above are internal business purposes under CCPA with the exception of the profiles described on this page related to targeted advertising to game players and our website visitors, which may constitute a “sale” under CCPA. You may have the cookies and related profiles that Unity holds deleted about you with respect to those uses of the cookie or AD ID; otherwise, Unity needs the information to carry out the internal business purposes described herein, including billing, fraud prevention, securing our systems, and assuring their integrity.
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
- Asset Store Sellers and Verified Solution Partners
- Verified third parties (when necessary to ensure safety, security, compliance with a legal obligation, or in the event of a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets)