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Unity Statement on GDPR Readiness
Unity Statement on GDPR Readiness
On May 25, 2018, the General Data Protection Regulation (GDPR) will become effective in the European Economic Area (EEA). This new regulation builds on the data privacy regulations in place in the EEA since 1995. The GDPR provides specific protections for individuals in Europe on how their data may be collected, moved, stored and processed.
On May 25, 2018, the General Data Protection Regulation (GDPR) will become effective in the European Economic Area (EEA). This new regulation builds on the data privacy regulations in place in the EEA since 1995. The GDPR provides specific protections for individuals in Europe on how their data may be collected, moved, stored and processed.
Last Updated: May 9, 2018.
Last Updated: May 17, 2018.
Unity Games and Data Collection
Unity Games and Data Collection
Unity is committed to the responsible collection and use of player data – and enhancing privacy safeguards. As such, if you are a developer or publisher that uses Unity Ads, Unity Analytics or any other Unity service, you can be confident that Unity is committed to GDPR compliance and will assist you with your technical preparations, including collaborating with your privacy and legal teams, so that you are aware of, and have confidence in, our GDPR implementation.
Unity is committed to the responsible collection and use of player data – and enhancing privacy safeguards. As such, if you are a developer or publisher that uses Unity Ads, Unity Analytics or any other Unity service, you can be confident that Unity is committed to GDPR compliance and will assist you with your technical preparations, including collaborating with your privacy and legal teams, so that you are aware of, and have confidence in, our GDPR implementation.
If you are a player of games made with Unity, or if you see ads in other games that are served by the Unity Ads SDK, we currently collect gameplay and device data. This data allows game developers and publishers to tune their games for player devices and to serve players with relevant advertisements about other games, movies and/or products that may interest them. These ads enable the developers and publishers to offer free-to-play games.
If you are a player of games made with Unity, or if you see ads in other games that are served by the Unity Ads SDK, we currently collect gameplay and device data. This data allows game developers and publishers to tune their games for player devices and to serve players with relevant advertisements about other games, movies and/or products that may interest them. These ads enable the developers and publishers to offer free-to-play games.
With the GDPR – and to be transparent about the data we collect and how it is used – we will be providing players with a data privacy option. On a game-by-game basis, players will be able to opt-out of data collection. As well, they will have access to Unity’s Privacy Policy (to be updated for the GDPR by May 25, 2018), and will be able to change their privacy setting any time they see an ad. Players who opt-out of data collection will still see ads, but these ads will be random and not tailored for the player.
With the GDPR – and to be transparent about the data we collect and how it is used – we will be providing players with a data privacy option. On a game-by-game basis, players will be able to opt-out of data collection. As well, they will have access to Unity’s Privacy Policy (to be updated for the GDPR by May 25, 2018), and will be able to change their privacy setting any time they see an ad. Players who opt-out of data collection will still see ads, but these ads will be random and not tailored for the player.
Frequently Asked Questions
Frequently Asked Questions
To clearly explain how Unity will comply with the GDPR – and how this will impact developers, publishers, and players – we have provided answers to common questions. We will update the FAQ as necessary. Contact us at GDPR@unity3d.com if you have questions not covered below.
To clearly explain how Unity will comply with the GDPR – and how this will impact developers, publishers, and players – we have provided answers to common questions. We will update the FAQ as necessary. Contact us at GDPR@unity3d.com if you have questions not covered below.
General Information
General Information
What kind of player data does Unity collect and what does Unity use it for?
What kind of player data does Unity collect and what does Unity use it for?
If a game developer or publisher enables Unity Ads or Unity Analytics for their game, we collect data such as device type, country, device language, in-game behavior and purchases, IP address, Apple’s Advertising Identifier (IDFA), and Google Play advertising ID. This information helps developers and publishers tailor games and ads for players and their devices, such as providing ads designed for specific device types, player languages, and game preferences.
If a game developer or publisher enables Unity Ads or Unity Analytics for their game, we collect data such as device type, country, device language, in-game behavior and purchases, IP address, Apple’s Advertising Identifier (IDFA), and Google Play advertising ID. This information helps developers and publishers tailor games and ads for players and their devices, such as providing ads designed for specific device types, player languages, and game preferences.
Why provide advertising at all?
Why provide advertising at all?
A great deal of creativity and resources go into making all games. Developers and publishers can provide free-to-play games because advertising helps cover their costs. As such, Unity tailors ad types and frequency so players have a better experience (for example, by seeing fewer but more relevant ads). This also allows advertisers to serve the most pertinent ads to players.
A great deal of creativity and resources go into making all games. Developers and publishers can provide free-to-play games because advertising helps cover their costs. As such, Unity tailors ad types and frequency so players have a better experience (for example, by seeing fewer but more relevant ads). This also allows advertisers to serve the most pertinent ads to players.
Does Unity collect what the GDPR refers to as “special categories” of personal information about players, such as political, religious, or sexual orientation?
Does Unity collect what the GDPR refers to as “special categories” of personal information about players, such as political, religious, or sexual orientation?
No. Unity only collects gameplay and device information. Unity does not collect these special categories of personal information.
No. Unity only collects gameplay and device information. Unity does not collect these special categories of personal information.
What is Unity’s strategy to assure GDPR compliance on May 25, 2018?
What is Unity’s strategy to assure GDPR compliance on May 25, 2018?
Prior to that date, Unity Ads will provide an updated SDK (see below for more information) and an Analytics plug-in and other resources to Unity game developers and publishers so they can provide players with a simple way to learn about and set their data privacy option. Unity is also working closely with other partners to ensure they are aware of these resources and changes.
Prior to that date, Unity Ads will provide an updated SDK (see below for more information) and an Analytics plug-in and other resources to Unity game developers and publishers so they can provide players with a simple way to learn about and set their data privacy option. Unity is also working closely with other partners to ensure they are aware of these resources and changes.
When will players be able to opt-out of data collection?
When will players be able to opt-out of data collection?
As of May 25, 2018, when a player begins playing a new free-to-play game, they will be presented with the opt-out option and a link to the Unity Privacy Policy. This will appear on the first ad they see in each game.
As of May 25, 2018, when a player begins playing a new free-to-play game, they will be presented with the opt-out option and a link to the Unity Privacy Policy. This will appear on the first ad they see in each game.
What will happen if a player opts-out of data collection?
What will happen if a player opts-out of data collection?
On a per-game basis, the player’s data will be deleted and the player will only see random, non-targeted ads or ads based solely on contextual data.
On a per-game basis, the player’s data will be deleted and the player will only see random, non-targeted ads or ads based solely on contextual data.
Will players be able to opt-in or opt-out of data collection at any time?
Will players be able to opt-in or opt-out of data collection at any time?
Each time a Unity ad appears in a game, players will be able to access and change their privacy setting via the Info “ℹ” icon on the Unity ad.
Each time a Unity ad appears in a game, players will be able to access and change their privacy setting via the Info “ℹ” icon on the Unity ad.
Information for Developers, Publishers and Other Partners
Information for Developers, Publishers and Other Partners
Is Unity classified as a processor or a controller when processing data under the GDPR?
Is Unity classified as a processor or a controller when processing data under the GDPR?
Unity is a processor with respect to developer data in Cloud Services, and a controller of player data that we collect via Unity Ads and Analytics.
Unity is a processor with respect to developer data in Cloud Services, and a controller of player data that we collect via Unity Ads and Analytics.
As a developer or publisher, do I need a new Data Processing Addendum (DPA) with Unity?
As a developer or publisher, do I need a new Data Processing Addendum (DPA) with Unity?
Unity Legal has added an updated Processor DPA and Controller-Controller DPA. They can be found here. The GDPR page will identify which documents apply to which services. Terms and Conditions for services will be updated prior to May 25, 2018, to provide appropriate references to these addenda as well.
Unity Legal has added an updated Processor DPA and Controller-Controller DPA. They can be found here. The GDPR page will identify which documents apply to which services. Terms and Conditions for services will be updated prior to May 25, 2018, to provide appropriate references to these addenda as well.
Will your Privacy Policy move from its current URL?
Will your Privacy Policy move from its current URL?
No. Our Privacy Policy will be updated to reflect certain new processes for players and the URL will remain the same. You may use the current link if you need to update your own privacy policy.
No. Our Privacy Policy will be updated to reflect certain new processes for players and the URL will remain the same. You may use the current link if you need to update your own privacy policy.
As a publisher, what should I do to be transparent with my players?
As a publisher, what should I do to be transparent with my players?
You should continue to notify your players about third-party ad partners (like Unity) that you share data with. You can do this by placing a link to our Privacy Policy within your own privacy policy. This is no different from the transparency Unity has recommended prior to the GDPR.
You should continue to notify your players about third-party ad partners (like Unity) that you share data with. You can do this by placing a link to our Privacy Policy within your own privacy policy. This is no different from the transparency Unity has recommended prior to the GDPR.
As a publisher, do I need to obtain consent from players about targeted advertising?
As a publisher, do I need to obtain consent from players about targeted advertising?
Unity will provide opt-out choices for behaviorally targeted advertising from anyone who sees a Unity ad. If you are not exclusively using Unity Ads, Unity can handle this for you through your mediation partners. Contact your Account Manager for more information. If you do not have an Account Manager, please contact support@unity3d.com.
Unity will provide opt-out choices for behaviorally targeted advertising from anyone who sees a Unity ad. If you are not exclusively using Unity Ads, Unity can handle this for you through your mediation partners. Contact your Account Manager for more information. If you do not have an Account Manager, please contact support@unity3d.com.
How will Unity allow players to decide if they receive targeted ads?
How will Unity allow players to decide if they receive targeted ads?
Unity will provide players with the ability to opt-out of targeted advertising. The first Unity ad that a player sees in each game will provide them with information about the data we collect, a link to our Privacy Policy, and the opt-out option. Players will be able to change their privacy setting any time they see a Unity ad via the Info “ℹ” icon.
Unity will provide players with the ability to opt-out of targeted advertising. The first Unity ad that a player sees in each game will provide them with information about the data we collect, a link to our Privacy Policy, and the opt-out option. Players will be able to change their privacy setting any time they see a Unity ad via the Info “ℹ” icon.
How can I let Unity know that I have obtained consent for targeted ads from my players outside of the Unity platform?
How can I let Unity know that I have obtained consent for targeted ads from my players outside of the Unity platform?
Unity will give publishers the ability to indicate that you have obtained consent from your own systems. If you would like to let Unity know that you will be obtaining consent outside Unity, please contact your Account Manager. If you do not have an Account Manager, please contact support@unity3d.com.
Unity will give publishers the ability to indicate that you have obtained consent from your own systems. If you would like to let Unity know that you will be obtaining consent outside Unity, please contact your Account Manager. If you do not have an Account Manager, please contact support@unity3d.com.
As a publisher, do I need to update my Unity Ads SDK?
As a publisher, do I need to update my Unity Ads SDK?
If you are using Unity Ads SDK 2.0 or newer, GDPR-related changes will be automatically available to you no later than May 25, 2018. If you are using SDK 1.5 or older, we recommend that you update the SDK; otherwise, Unity can only serve contextual ads for your players.
If you are using Unity Ads SDK 2.0 or newer, GDPR-related changes will be automatically available to you no later than May 25, 2018. If you are using SDK 1.5 or older, we recommend that you update the SDK; otherwise, Unity can only serve contextual ads for your players.
What does opting-out of Unity Analytics mean for a player?
What does opting-out of Unity Analytics mean for a player?
Players will be able to opt-out of Unity Analytics on a per-game basis. If a player chooses to opt-out, Unity Analytics will no longer optimize game experiences based on their in-game behaviors.
Players will be able to opt-out of Unity Analytics on a per-game basis. If a player chooses to opt-out, Unity Analytics will no longer optimize game experiences based on their in-game behaviors.
How will Unity allow players to opt-out of Analytics?
How will Unity allow players to opt-out of Analytics?
Similar to Unity Ads, you will be able to give players the ability to opt-out of data collection via a plug-in that you can integrate into your games. Integrating the plug-in will only be necessary if you are not using Unity Ads. It will be provided prior to May 25, 2018.
Similar to Unity Ads, you will be able to give players the ability to opt-out of data collection via a plug-in that you can integrate into your games. Integrating the plug-in will only be necessary if you are not using Unity Ads. It will be provided prior to May 25, 2018.
Information for Users of Developer Services
This section covers Unity Collaborate, Cloud Build, Performance Reporting, and Bug Reporting (Alpha).
General Information
In the context of Developer Services and the data it collects, Unity is a processor of data. The customer (“developer”) is the controller.
In regards to “personally identifiable information” (PII), Developer Services maintains a Name/Public User ID in the form of project history. For example, when a developer makes a change to a project, that change is recorded and communicated to other team members. To “forget” that user, Developer Services will provide functionality allowing a developer to “mask” their historical activity upon request.
What creator data is collected by Developer Services?
Developer Services collects project-related data such as project assets, code, developer activity, and credentials, as provided by the developer to Unity.
How is the data used?
Unity is a processor of the data, and uses the data provided by the developer (who is the controller of the data) to fulfill tasks and services that the developer chooses. For example, tasks and services include:
Project assets stored in Cloud Storage to secure files and enable Collaborate features.
Developer activity recorded by Unity to show and manage the historical state of a project in Collaborate.
Project credentials to access project assets and automatically create builds for the developer via Cloud Build.
How long is data retained?
Project data, including backups, is retained for a finite period. The retention policy varies depending on the nature of the primary service processing it. A developer can manually delete data at any time via features provided by the service, or by contacting Unity at support.unity3d.com.
In addition to using data to deliver services that the developer has opted into, Unity may also use data to identify and target individual developers to further the Unity business, including requests for product feedback and exposure to marketing materials. Developers have the ability to opt-out of these communications.
What player data is collected by Developer Services?
Through reporting features – Performance Reporting, Bug Reporting (Alpha) – Developer Services collects error reports generated by an application made with Unity and information about the device it was collected on. Device information includes data that could be considered personal data (machine ID), but this information is anonymized before it is retained.
In some cases, a developer may send PII to Unity inadvertently. For example, with features provided via Bug Reporting, a player could share a screenshot that includes the player’s in-game name. Unity does not identify or data-process information collected in this fashion.
How do I inquire about a GDPR-related issue concerning Developer Services?
You can create a ticket at support.unity3d.com and your request will be acknowledged and prioritized.
Further Information
Further Information
If you have any questions not addressed above, please contact us at GDPR@unity3d.com.
If you have any questions not addressed above, please contact us at GDPR@unity3d.com.