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Privacy Policy for individual Indie developers apps

Discussion in 'General Discussion' started by Nekuneku, Sep 10, 2018.

  1. Nekuneku

    Nekuneku

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    Hi everyone,

    I'm a newbie individual indie developer and I don't have a studio or a company, and in order to get my game on the app store I will need a privacy policy.
    I found this website https://app-privacy-policy-generator.firebaseapp.com/ that generates that for you after filling basic info, will my name will be enough or the correct thing to put since I don't have any company or studio? I'm not sure if this is safe to do

    Any advice from anybody with experience in this field will be much appreciated

    Thank you very much for your time

    Cheers
     
    Rodolfo-Rubens likes this.
  2. Antony-Blackett

    Antony-Blackett

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    What's stopping you from registering a company?

    It's a little bit of paperwork now, but it's worth it long term, especially if you intend to be in the business for a while and potentially grow in future.
     
    Nekuneku likes this.
  3. Nekuneku

    Nekuneku

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    Isn't that a huge step or " too early " for someone who just started his first app?
     
  4. Antony-Blackett

    Antony-Blackett

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    Completely the opposite! The longer you leave it and the bigger your app gets the more work it will be to transfer the ownership of that app from yourself to your company. In my current country of residence you even have to pay tax to do the transfer, and that tax is a % of the 'value' of the app. Where as if you just start the app in that company, then there'd be no tax to pay.

    Obviously this is going to be different from country to country and you really need to get some advise from someone who knows your local rules (Accountant).

    But there are other reasons as well, which is more to the topic of your post. Companies can offer you protection in case something goes wrong. If you create a privacy policy and it is later deemed that you broke that privacy policy with a customer you could be personally liable for any 'damages' that customer endured. That means all your assets (house, car, and app), could be taken to pay that liability.

    That is a worst case scenario, but it isn't impossible. The bonus of making a company and placing your app in that company is you can at least protect yourself, your personal cash and assets such as house, car, possessions from legal problems down the road.

    The final and most important benefit of getting accounting and legal advice now is that you'll avoid legal trouble to start with. It may seem like a lot of money and hassle up front, but... if you are serious about making your game into a business then you should take it very seriously.

    "I didn't think my game would do that well." is not a legal defence.
     
  5. angrypenguin

    angrypenguin

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    It doesn't have to be. There's a bunch of stuff you really need to understand if you go down this route, like your local laws and responsibilities for owners of companies. So don't do it without due research and consideration. But if you're cool with that stuff then there are services that will set you up with a company in under 24 hours for a modest fee.

    Do definitely get advice from a local expert. But no, it doesn't have to be a "huge step".
     
    Socrates and Nekuneku like this.
  6. Nekuneku

    Nekuneku

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    Thank you everyone for the information provided , I never expected the importance of this especially in this early stage,
    I will definitely look this up and do my research before taking the next step
     
    Last edited: Sep 10, 2018
  7. Antony-Blackett

    Antony-Blackett

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    Yeah, it's a common feeling, it seems so easy and trivial to just upload and release an app. But the reality is that you are releasing a game and people that download and play that game for free or paid put the same demands of trust and security on you as they would EA or any other developer.
     
    Nekuneku likes this.
  8. JamesArndt

    JamesArndt

    Unity Technologies

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    You'll also need to comply with the GDPR regulations if anyone in the EU downloads your app (highly likely on app stores). A simple privacy policy won't cut it. The fines for violating the regulations would pretty much put a small developer out of business in most countries. Luckily Unity has a GDPR package on the asset store that I believe will set up the consent forms for opt-in within your game. This is very important if your game is using Ads or Analytics. Even if it uses neither, the Unity Editor and its builds are embedding analytics into your app. This can be disabled if you use Unity Pro by unchecking the "Disable HW statistics" button in the Inspector.

    https://eugdpr.org/

    "If you are not using Unity Ads, but are using any other Unity service (Analytics, IAP, Performance Reporting, Multiplayer, etc.) or have a game with HW Statistics enabled, then you can use the Analytics Data Privacy plug-in. "
     
    Last edited: Sep 20, 2018
    URPian and Nekuneku like this.
  9. Nekuneku

    Nekuneku

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    Thank you very much for your insight and the information you provided ,
    I'm not using unity ads, I'm using AdMob, this is for the free version of my app the second version is a paid one and it doesn't contains ads and I turned off all Unity services like Analytics,
    You said Unity editor embeds analytics into builds ,does that happen even if all the services are turned off? do i need to get Unity Pro to disable "HW statistics" ? because I'm using Unity personal
     
    JamesArndt likes this.
  10. JamesArndt

    JamesArndt

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    Unity Pro will give you the option to not acquire any player data because in Pro you can turn off Unity's hardware information collection. In Unity Personal it's there but you will need to get the Data Privacy Policy package from the Asset Store and set that up. I think it's this one. https://assetstore.unity.com/packages/add-ons/services/unity-data-privacy-plug-in-118922

    You'll need to look up their pages for this though to be sure which one you need for the built-in Unity hardware information stuff.
     
    Solphist and Nekuneku like this.
  11. Nekuneku

    Nekuneku

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    Thank you so much for your help !!
     
  12. Ostwind

    Ostwind

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    BTW you can also disable the checkbox with Unity Plus so it's not limited only to Pro.
     
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  13. JamesArndt

    JamesArndt

    Unity Technologies

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    Oh, I wasn't aware. I'm assuming Unity Plus puts it behind a paywall as well? I do believe there is some way to "firewall" your app or game and prevent any network activity whatsoever, that's what Reddit is suggesting.
     
  14. Ostwind

    Ostwind

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    You could say that. However I was not able to reply in the other thread since it got locked but back in April or May when the GDPR was a hot topic I remember seeing an Unity employee saying to someone somewhere that analytics of the editor and the the Unity player (build) are both GDPR compliant under recital 26 as both are hashed/anonymous data. This would allow them to keep them enabled on the Personal edition with no option to disable.

    This however might break some points of the EULA.
     
    JamesArndt likes this.
  15. JamesArndt

    JamesArndt

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    I figured that second point would be some kind of TOS violation, but now im curious. Is it a EULA violation to block all network activity in your app?

    As for the first point. I think that was a source of a lot of confusion. The built in hardware stats seem to "take first, ask questions later" approach to the user hardware data. A lot of people wrote this was a violation of the EU law in and of itself regardless if you scramble the data after the fact. I'm still not sure myself.

    I'm assuming that because no personally identifiable data is stored in hardware stats that there is no need to opt-out in an app not using any network services.
     
    Last edited: Sep 21, 2018
  16. Ostwind

    Ostwind

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    I would assume it depends how such blocking would be achieved, ie. would one byte patch network related Unity code to always fail. Regardless of the way it would also remove the ability to do multiplayer, online news, highscores etc. unless the sole purpose is the is to disable Unity stats.

    Yeah consent is not required when no personal data is gathered, which the stats behind the checkboxes do AFAIK. Unity ads or other analytics gather more which is why you need to show the dialog.
     
    JamesArndt likes this.
  17. Wicked_Manatee

    Wicked_Manatee

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    For those finding this later, the GDPR asset linked above is outdated and no longer in use.
    "Assets\DataPrivacy\Runtime\DataPrivacy.cs(2,8): error CS1029: #error: '"The Data Privacy Plugin is included in the Analytics Library Package and is not longer needed. Please remove this plugin."'
     
    JKrypto likes this.
  18. porandojin1

    porandojin1

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    It doesn't seem outdated on asset store, but I get the same error...
    Do you know what is the current alternative, @Wicked_Manatee?
     
  19. Antony-Blackett

    Antony-Blackett

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    I think it’s just builtin to the latest analytics package
     
  20. Meltdown

    Meltdown

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    Not sure about your country's laws, but in most places any expense incurred by your business is tax deductible, meaning you only get taxed on your business profits.

    I would email an accountant and ask them about the benefits, most should be able to give you a free consultation, in the hope you'll become a customer.
     
  21. LucasGHL

    LucasGHL

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    Sorry for asking this, I am a newbie. But if I want to upload the privacypolicy URL to google play, do I need to make a web for this?
     
  22. Meltdown

    Meltdown

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    Yes, you'll need to make a website with your business domain, and upload the page to it. Then link to that page.