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Age designation

Discussion in 'Unity Analytics' started by sschan, May 19, 2015.

  1. sschan

    sschan

    Unity Technologies

    Joined:
    Oct 8, 2014
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    Unity Technologies is excited to announce another important milestone - developers of apps directed to children under 13 can now use Unity Analytics.

    Developers building apps directed to children under 13 in the United States are required to comply with the Children’s Online Privacy and Protection Act (COPPA) https://www.ftc.gov/enforcement/rul...ings/childrens-online-privacy-protection-rule), a federal law that is designed to protect the online privacy of children in the United States.

    Unity Analytics supports internal operations of gaming services, websites, apps, and games. The Unity Analytics Service can help game developers:
    1. Provide game usage and performance analytics
    2. Understand game performance and monitor game health and areas of crashing
    3. Improve game design and green lighting
    4. Deploy future game development resources based on game performance
    5. Maintain or analyze the functioning of games, including through maintenance, analysis and analytics
    6. Protect the security and integrity of game players
    7. Serve contextual advertising and cap the frequency of advertising
    8. Ensure legal or regulatory compliance
    This document is provided for information purposes only and should not be considered legal advice or a substitute for obtaining your own legal advice. Developers must independently ensure their compliance with COPPA of a child directed app.

    Frequently Asked Questions

    1. What information does Unity Analytics collect?
    In order to provide analytics for your games, Unity Analytics collects and uses in each game built with Unity Editor an anonymized user ID. Each ID is unique to users on each developer’s apps. These IDs cannot be used to track users across apps built by other developers and cannot be mapped between different services, devices, or even different browsers on the same computer. For further information, please review the Unity Privacy Policy: https://unity3d.com/legal/privacy-policy.

    2. What is the anonymized user ID used for?
    The anonymized user ID is used to track the activities of game players in order to help developers: (i) provide game usage and performance analytics; (ii) understand game performance and monitor game health and areas of crashing; (iii) improve game design and green lighting; (iv) deploy future game development resources based on game performance; (v) maintain or analyze the functioning of games, including through maintenance, analysis and analytics; (vi) protect the security and integrity of game players; (vii) serve contextual advertising and cap the frequency of advertising; and (viii) ensure legal or regulatory compliance

    3. How will Unity know if my application is directed to children under 13?
    When developers download the Unity editor and integrate Unity Analytics into their project, they will be required to indicate whether the application they are building is directed to children under 13 as addressed in the Children’s Online Privacy Protection Rule. Developers are solely responsible for making this determination. Developers may seek COPPA guidance from the Federal Trade Commision, who provides a wealth of COPPA resources at: https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children's-privacy

    4. If my game is developed outside the United States and not directed to any children located in the United States, what designation should I make?
    You can select the option “This game is not directed to children under the age of 13 in the United States”.

    5. What about my existing apps using Unity Analytics?
    All existing apps using Unity Analytics will be designated as not directed to children under 13 unless you affirmatively change the designation.

    6. Does the Unity Analytics Service ensure that my Unity app/game is COPPA-compliant?
    Unity Technologies does not make any express or implied warranties or representations that the Unity Analytics Service is COPPA compliant, and you should not rely on the Unity Analytics Service to satisfy your COPPA obligations. It is your responsibility to ensure your Unity app/game is COPPA compliant.
     
    Last edited: Jun 1, 2015
    joca2202 likes this.
  2. eezSZI

    eezSZI

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    Yay! Thank you for this update.
     
  3. manutoo

    manutoo

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    I'd like some clarifications about "directed to children under 13".
    My game is for all players, whatever age they have, so I guess my game is (also) "directed to children under 13", right ?
     
    sivrikaya likes this.
  4. mpinol

    mpinol

    Unity Technologies

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  5. manutoo

    manutoo

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    @mpinol,
    thanks for your answer.
    I did a bit of reading and I found this : http://www.coppalawattorney.com/the-directed-at-children-standard-of-coppa/ .
    My understanding from it is that actually my game is not directed to children, as its main target is more mature (ie: some mild violence and somewhat mature language), even if it's not impossible for kids to play it.
    Moreover, Unity Analytics doesn't seem to collect any personal information (even not the IP if I read the FAQ above correctly), so there's no need to comply with the COPPA if I don't personally add collection of personal data.
     
  6. goat

    goat

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    Both GooglePlay and ESRB.org allow you to self-rate and to have your game as described be rated Everybody wouldn't be allowed according to their descriptions.
     
    manutoo likes this.
  7. ayellowpaper

    ayellowpaper

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    Dec 8, 2013
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    Thanks for the great post! But I couldn't find anywhere what the restrictions are when I choose to target children under the age of 13. Less data? And is it needed to make a build for US where the checkbox is selected and another build for all other countries or does UnityADs take care of that?

    Thanks in advance!
     
  8. mpinol

    mpinol

    Unity Technologies

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    Jul 29, 2015
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    Hi @ayellowpaper

    https://www.ftc.gov/tips-advice/bus...ying-coppa-frequently-asked-questions#General Questions

    COPPA deals with the collection of personal information for children under the age of 13. Section A should give you all of the information on what defines 'personal information' and how to be compliant. I can only speak for Unity Analytics so any questions about Unity Ads should be posted on their forums, http://forum.unity3d.com/forums/unity-ads.67/

    Hope this helps and let us know if you have any more questions.
     
  9. Fissll

    Fissll

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    Jan 30, 2015
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    This thread didn't help me at all :(

    First of, English is not my native language and also I am not very good at law stuff.

    So here's my question:
    My game is going to be a simple non-violent casual game which can be played by anyone and it will also have AdMob, UnityAds and Unity Analytics integrated (no additional data is being collected by "me").
    I guess I should pick the option that my game is indeed directed to children under the age of 13, right?
    But do I need to do something if I tick this box or do I have to state that data is being collected in this game?
    I just don't get the idea behind COPPA and how to be "compliant" ... it's confusing the sh*t out of me :confused:
    Also what changes if I tick the box that my game is directed to children?
    Do I get less data or what?

    Any help is appreciated, thanks.
     
  10. marc_tanenbaum

    marc_tanenbaum

    Unity Technologies

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    Oct 22, 2014
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    295
    @Fissll
    Yes, if your game's audience includes children under 13, you should indicate that it is directed at kids under 13. This is required under US law. Ticking the box doesn't change anything for Analytics. You won't get less data. It's simply your agreement with us that you promise to keep your use of data consistent with applicable law.

    Ads handles COPPA-compliance by not collecting certain types of personally identifying information, and this can diminish ad effectiveness (and therefore potentially impact your income). I recommend you ask on the Ads forum, where someone more knowledgable than myself can be more precise.

    Now, the particulars of law are highly dependent on your use (what are you showing? which countries are you releasing in? etc) and we're not allowed to give you legal advice, such as "do I have to state that data is being collected?" For that you probably need to ask a lawyer.

    Hope that helps!
     
    Fissll likes this.
  11. Fissll

    Fissll

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    Jan 30, 2015
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    Thank you for your answer @marc_tanenbaum ,

    So basically for the Analytics part I just have to tick the box and I'm good?

    Because like I said, I will just use the basics of Analytics ... I won't try to get the players name or his address or something like that.

    Also I think it is kinda odd that you can't change if your game is directed to children or not after you set it once :-/
     
  12. Actio

    Actio

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    Apr 30, 2014
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    Is there a way to change the age designation?
     
  13. Fissll

    Fissll

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    As far as I know, you have to create a new project
     
    Actio likes this.
  14. b3ka

    b3ka

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    Dec 10, 2014
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    Hi,

    I am on the verge of releasing my first game and I just came across the problem of COPPA. I have some open questions regarding COPPA compliance and Unity Analytics which reading through the docs could not answer. Please bear with me, my post is long but I tried to summarize my understanding which may help other developers as well.

    As far as I see if a developer does not actively implement some data collection (birthdate, userid, gender -> considered optional user attributes in Analytics) the question regarding COPPA complience in connection with Unity Analytics breaks down to the following:

    - Is the "anonymized user ID" in #1 of the FAQ above (in itself or together with gameplay event data) sufficient to identify the user or his device? Reading through (not always clear) Unity announcements and Privacy Policy I would assume that this ID is hashed therefore not backtrackable to the originating device. Where this hashing is done? Because if on the server side than basically that means UA _is_ collecting PII but not storing it! Is the ID different for different apps of the _same_ developer too?

    - From my understanding collecting IP address can also be seen as PII. So far I could not find any reassuring information otherwise. Does UA collect _and_ store IP addresses or storage is on a regional, city, or otherwise aggregated level?

    - I am not really sure if COPPA includes the right for the parent to ask for deletion of _any_ collected or just PII data. And my concern is how the deletion process would look like in case of UA? I suppose the developer needs to ask, but with what ID the developer can refer to the data items in question? Of course based on my first and second point the deletion could be totally unneccessary (since there is no PII stored).

    - Is there any way a developer could see samples of the raw data sent to Unity Analytics to get reassurance that the packages do not contain any COPPA non-complient information?

    - Is (or will be) un-aggregated data available on Unity Analytics? So far I could not see such, but as soon as it is available, even more concerns may arise.

    Thank you in advance for answering my concerns!
     
  15. mpinol

    mpinol

    Unity Technologies

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    Jul 29, 2015
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    Hi @b3ka,

    Alright, here we go!

    The anonymized user ID is generated on the device itself and is different across all apps regardless of developer. An example of this is that if a player uninstalls and then reinstalls a particular app, they will receive a newly generated user ID as soon as the app is launched.

    Yes we collect IP addresses for use in geographic segments, by country, on the Dashboard.

    Since there is no PII collected there should be no need to delete a particular user's data but if deletion was required, and unless the user ID was known, the entire project would need to be deleted as the only known ID would be the project ID.

    As of right now I do not believe that there is any way to see the raw data sent to Analytics without using 3rd party software.

    We are testing a raw data export feature that would give developers access to their raw un-aggregated data but I cannot give you any real time frame of when it will become available to everyone and it also will not contain any personally identifiable information.

    Let me know if you have any more questions!
     
  16. pouya90

    pouya90

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    Feb 28, 2015
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    hi , I have selected the children under the age of 13 but now I want to change it and I can't find it how , can you help me with this ?
     
  17. mpinol

    mpinol

    Unity Technologies

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  18. AntoineDesbiens

    AntoineDesbiens

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    Just read this on the COPPA faqs
    https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions

    Along with the IPs, your privacy policy states that analytics are also collecting device identifiers.

    This is also part of COPPA faqs
    As far as I understand, a parent COULD ask the developer to delete the PIIs and with the current state of unity analytics, request of data deletion isn't really supported.

    Basically, at the moment, it's impossible to use analytics/IAPs and have users of our playerbase be less than 13 without being at risk of legal issues, does that make any sense? Unless I missed/misunderstood something?
     
    Marc81 likes this.
  19. markychoi

    markychoi

    Unity Technologies

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    Aug 4, 2014
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    Hi @Fujik,

    Unity Analytics supports internal operations of gaming services, websites, apps, and games. Further along in the FTC FAQ, the FAQ does seem to provide additional information related to how COPPA may apply to using a service like Unity Analytics and collecting "personal information" like IP address and device identifier.

    In particular, I would check out sections C.6 and I.5-8 that provide more information around what "support for the internal operations of the Web site or online services" means and the resulting implications for your app.

    Hope that helps! As a reminder, we encourage all our developers to procure their own qualified legal help to understand the various rules and regulations, to ensure compliance with COPPA of a child-directed app. Anything we provide here is for informational purposes only and should not be considered legal advice or a substitute for obtaining your own legal advice.
     
    AntoineDesbiens likes this.
  20. Marc81

    Marc81

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    Feb 7, 2014
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    Dear Unity Support,

    hopefully you can get some clarification here, I think the very simple question everyone is trying to get an answer for is this:

    Is Unity Analytics COPPA compliant?

    Let us assume I create a blank new project in Unity and add Analytics with the setting "This game is directed to children under the age of 13 in the United States." and publish it. I have not added any code whatsoever. Is my application in compliance with COPPA?

    Are you able to answer this question with a clear yes?

    Because if you are not able to, as Fujik stated before, no one can use Analytics without being at risk of legal issues...

    Thanks!
     
    Fissll likes this.
  21. marc_tanenbaum

    marc_tanenbaum

    Unity Technologies

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    Oct 22, 2014
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    @Marc81

    Unity Analytics provides a COPPA-compliant solution for games designated as directed to children under the age of 13. If you flag your game as such when creating a project, Unity Analytics then collects data and operates consistent with COPPA limitations. Determining whether a game is “directed to children under the age of 13” under COPPA has to be made by each developer based on characteristics of the game and its audience. Unity unfortunately cannot make this determination.
     
  22. Brutusomega

    Brutusomega

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    Jul 30, 2013
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    Can i change a project that is COPPA compliant to a non COPPA compliant project?
     
  23. erika_d

    erika_d

    Unity Technologies

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    Jan 20, 2016
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    Hi @Brutusomega,

    At the moment COPPA compliance cannot be changed on a project once it's been set. Currently the best workaround available would be to create a new project on the Analytics Dashboard and then re-link your Unity project to the newly created Analytics Dashboard project from the Services window.
     
  24. goat

    goat

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    So, OK, I am clear now - game rated Everyone+ must choose to follow the COPPA requirements for targeting childen under 13 even if the game isn't marketed to any particular demographic. The wording makes it sound as if you are even if you aren't.

    At any rate, they would do well to consider raising that age to 18 years old if one is to believe the how the rest of the USA laws on age of consent work.
     
    erika_d likes this.
  25. CHG_Eve

    CHG_Eve

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    Sep 21, 2014
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    A question that is still not sufficiently answered here is about the use of IP adresses. @mpinol states that IP adresses are collected but that there is no PII collected. Which is contradicting, since an IP is regarded as personal information according to COPPA.

    How can the Analytics be compliant with COPPA when IPs are collected and cannot be deleted if a user want's it to?!
     
  26. APalomo

    APalomo

    Unity Technologies

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    Aug 3, 2016
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    @CHG_Eve

    Unity Analytics provides "support for the internal operations" of your game or app, which is a case the FTC FAQ takes into account.

    If you have any specific questions about your game and COPPA, we advise you to contact your personal legal counsel.
     
    Last edited: Nov 18, 2016
  27. roberto_sc

    roberto_sc

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    Hi! How does Unity collect demographics info (gender and age)? I saw these in the Segment Builder section in the Analytics page. Or better, what do I have to implement in order to collect these information?
     
  28. APalomo

    APalomo

    Unity Technologies

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    roberto_sc likes this.
  29. anajames86

    anajames86

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    Thanks for the update, good share.
     
  30. HarBenly

    HarBenly

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    Nice. Good share.