Unity Technologies Privacy Policy changes — 20200902_rev01

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- _Please note Unity does not discriminate in its provision of services to you based on exercising your rights._

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- _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._

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- _You may ask a third party representative to assist you in exercising your rights. Third parties may write to [DPO@unity3d.com](mailto:DPO@unity3d.com) to provide documentation of their right to act on your behalf. If you are a game player, we will not have a way to locate records about your outside of an app using Unity's software, but you may direct your reports to be sent to your representative once you have verified your identity inside of the app. Unity 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 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._

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- _More information on your rights as a Californian and instructions on how to exercise them with Unity may be found [here](https://unity3d.com/legal/do-not-sell-my-personal-information)._

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- __You may view our CCPA Transparency Report at [https://unity3d.com/legal/privacy-report](https://unity3d.com/legal/privacy-report). This report provides details on our responses to requests to access, delete or opt-out under CCPA.__

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_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](mailto: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](mailto:DPO@unity3d.com).

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- _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](https://unity3d.com/legal/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](http://www.allaboutdnt.com/).

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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:

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- **Right to Access** - You have the right to request Unity provide you with a copy of your personal data.

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- **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.

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- **Right to Erasure (Deletion)** - You have the right to request Unity to erase your personal data, under certain conditions.

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- **Right to Restrict Processing** - You have the right to request Unity to restrict the processing of your personal data, under certain conditions.

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- **Right to Object to Processing** - You have the right to object to Unity's processing of your personal data, under certain conditions.

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- **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.

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To exercise the above rights, email [DPO@unity3d.com](mailto:DPO@unity3d.com) (or contact us as indicated in the 'Contact Us' section below). In some cases a Unity customer, such as a game developer, may be the controller of your data and Unity only a Processor. In this case, Unity will direct you to its customer, and Unity will support its customers in responding to requests as required by law.

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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](mailto:dpo@unity3d.com) if you wish to discuss any complaint. You can find your supervisory authority [here](https://edpb.europa.eu/about-edpb/board/members_en).

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## 13\. Links to Sites and Service Operated by Others

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The Unity Service may contain links 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.

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## 14\. Contact Us:

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 **Last Updated: May 27, 2020**
+Last Edit/Review: July 1, 2020
+Last Edit/Review: August 17, 2020
 ## 1\. Frequently Asked Questions (FAQs)
 These FAQs provide a handy entry point to our longer and more comprehensive Privacy Policy (see Section 2 below). They are intended to enhance rather than replace the important notices in the Privacy Policy, which governs our collection, use, storage, and sharing of the information that we collect or receive from you.
 ### What's new as of May, 2020?
+On July 1, 2020, we made an edit to Section 12 to add a link to our California Consumer Privacy Act Transparency Report.
+On August 17, 2020, we made an edit to Section 12 to provide an additional summary of rights for data collected in Europe.
 On May 27, 2020, we made the following updates: We are updating our policy to include a reference to our service provider's privacy statement in Section 5. We are notifying you by asking you to accept this new policy to be sure you see this update. Please note if you do not pay your Unity fees by credit card, this change has no effect on you. Other changes on May 27, 2020 include an addition of three partners in Section 16 for ads network partners. Note players in the European Union have had this information available to consider prior to today; however, we will only now begin sharing ads data with those partners for EU players. Finally, we have added a section about features involving Unity's access to cameras on devices. You will note there is similar language in the consent we request for access to the camera, and we do not collect images from your device at this time.
 Additionally, as of March 10, 2020, we are adding a last edit/review date. The difference between an edit/review and an update is that "updates" involve material changes to our policy whereas edits are not material or simply indicate a review has occurred. For example, we may make clarifying edits by giving additional examples. When we provide an update, you receive a notice to accept and read the changes, which are summarized in this first FAQ.
 As reminder, we enhanced our FAQs in May 2018 to provide more examples of how we may use some of the data we collect. These answers enhanced our prior explanations but are not intended to imply that these are new uses of collected data. Additionally, if your data indicates you are in the European Economic Area (EEA), we have added information regarding new choices enabled for in-game advertising, and information on how you can exercise your data access and deletion (erasure) rights. We have added the l"Data Privacy" icon to our ads, dashboards, and other points of interaction:
 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.
 ## 11\. Changes to This Privacy Policy
 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.
+## 12\. California Privacy Rights
+## 12\. California & EU Privacy Rights
 - _Please note that Unity has placed a new [California Notice of Rights](https://unity3d.com/legal/do-not-sell-my-personal-information) on its website 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_
+    _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](mailto: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](mailto:DPO@unity3d.com).
 . _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;_
 . _An ability to appoint a third party representative to assist you with exercising your rights and,_
     - _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](mailto:DPO@unity3d.com) to provide documentation of their right to act on your behalf. If you are a game player, we will not have a way to locate records about your outside of an app using Unity's software, but you may direct your reports to be sent to your representative once you have verified your identity inside of the app. Unity 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 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](https://unity3d.com/legal/do-not-sell-my-personal-information)._
     - __You may view our CCPA Transparency Report at [https://unity3d.com/legal/privacy-report](https://unity3d.com/legal/privacy-report). This report provides details on our responses to requests to access, delete or opt-out under CCPA.__
+    _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](mailto: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](mailto:DPO@unity3d.com).
 - _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](https://unity3d.com/legal/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](http://www.allaboutdnt.com/).
+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.
+To exercise the above rights, email [DPO@unity3d.com](mailto:DPO@unity3d.com) (or contact us as indicated in the 'Contact Us' section below). In some cases a Unity customer, such as a game developer, may be the controller of your data and Unity only a Processor. In this case, Unity will direct you to its customer, and Unity will support its customers in responding to requests as required by law.
+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](mailto:dpo@unity3d.com) if you wish to discuss any complaint. You can find your supervisory authority [here](https://edpb.europa.eu/about-edpb/board/members_en).
 ## 13\. Links to Sites and Service Operated by Others
 The Unity Service may contain links 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.
 ## 14\. Contact Us:

Privacy Policy

Full text changes — 20200802_rev01 to 20200902_rev01