Privacy overview

The Lobby service provides a way for players to discover and connect to each other to accomplish a variety of multiplayer gaming scenarios. The Lobby can persist for the duration of the game session to provide a mechanism for users to re-join an existing game session or facilitate host-migration after an unexpected disconnect.

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 (always collected in order for product to work)

  • IP address
  • Authentication Player ID

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

  • N/A

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.

Legal basis for processing

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

Consent

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

Two of the most common data subject requests based in law are the request for access to personal data and the request for deletion of personal data.

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 reaching out to the Unity Gaming Services support team with the Player ID of the end user that requested access.

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 reaching out to the Unity Gaming Services team with the Player ID of the end user that requested data deletion.

Please note: This functionality only applies to this service. If you are using other services which collect app user personal data you will need to review that service's documentation for how it handles data access requests. To delete the Player ID created by the Unity Authentication SDK (if enabled), please use the Authentication API.

Dependencies

This product is dependent on the Unity 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

Lobby does not store IP Addresses or Player ID. However, the Player ID in Lobby logs has a retention period of 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 (DPA)

The 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.
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