Privacy overview#

Product Overview#

Cloud Code offers serverless computing to RT3D backend developers. In parallel, it acts as the conductor in the Unity ecosystem, allowing developers to put in place a Server Authoritative Game Logic with UGS Services.

This documentation is intended to assist products to display their privacy compliance to Developers. It is not intended to be used as legal guidance or as a replacement to reading Unity’s Privacy Policy. If you have questions about a term used, please see the Glossary below.

If you have further questions about the privacy implications of your product, please email DPO@unity3d.com with your question. For expediency, please list the product about which you are inquiring.

Personal Data Collected about App Users/Game Players#

Default Personal Data Collected

1. Authentication Player ID
2. Unique installation-specific ID
3. User ID – Custom Id for Analytics (if available)

Optional Personal Data Collected (personal data which may be collected at action of the Developer)

Developer Defines#

While this product allows for the collection of developer defined data, we require that you not collect personal data through this mechanism. Our systems will not understand that it is personal data and so such would not be treated as such in retention processes or data subject requests.

Relationship under Privacy Laws#

Under GDPR, Unity is the Processor. You, the developer, are the Controller.

Under CCPA (as modified by CPRA), Unity is the Service Provider. You, the developer, are the Business Provider.

Legal Basis for Processing#

As we are a Processor, we do not determine the legal basis for processing. Instead, it is your responsibility as the Controller to determine such a legal basis.

Consent (Opt in) vs Opt out#

This product does not have a consent service. If the Developer determines they need to obtain consent, or provide an opt-out, they must implement it client-side in a way determined by the developer.

Data Subject Requests#

Access#

This service has no native functionality to support data access requests. You, the developer, are responsible for actioning them. You can action them by filing a ticket in the Help and Support section of the Unity Cloud Dashboard.

Deletion#

This service has no native functionality to support data deletion requests. You, the developer, are responsible for actioning them. You can action them by filing a ticket in the Help and Support section of the Unity Cloud Dashboard.

Dependencies#

Depending on how you enable it, this product may be on the Authentication product. By enabling this product, you will also be enabling the Authentication product and you should refer to Unity Authentication SDK for more information.

Data Retention#

Personal data collected by Unity is stored for up to 30 days.

Child Privacy#

If required to do so under applicable laws, you (the developer) must obtain Verified Parental Consent prior to submitting child-user data, as outlined in the Unity Terms of Service.

Privacy Policy Requirements#

It is never appropriate to use Unity’s privacy policy for your application. You will need to ensure that the personal data practices are reflected in your Privacy Policy, as required in the Unity Terms of Service.

Data Processing Agreement#

Unity DPA applies to the transfer of data for this product.

Glossary & Notable Laws#

• GDPR - The General Data Protection Regulation (GDPR) took effect in the European Economic Area (EEA). References to GDPR also encompass UK GDPR which is the UK’s version of GDPR which applies post-Brexit.
• CCPA - The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (“CPRA”).
• PIPL - In November of 2021, Personal Information Protection Law (PIPL) took effect in China.
• LGPD - The Brazilian General Data Protection Law
• VCDPA - The Virginia Consumer Data Protection Act
• CPA - The Colorado Privacy Act
• CTDPA - The Connecticut Data Protection Act
• UCPA - The Utah Consumer Privacy Act
• PIPEDA - The Canadian Personal Information Protection and Electronic Documents Act
• COPPA - The Children’s Online Privacy Protection Act (COPPA) imposes restrictions on how data can be collected and used from children under the age of 13.
• CARU - A self-regulatory organization for the promotion of responsible privacy practices to children under the age of 13
• DPA - A Data Processing Addendum (or Data Processing Agreement) forms part of a contract and governs the rights and obligations of each party concerning the processing of personal data.
• ATT - iOS 14 and later requires publishers to obtain permission to track the user's device across applications. This device setting is called App Tracking Transparency, or ATT.