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Privacy Policy

Discussion in 'Unity Analytics' started by Thajocoth, Jul 21, 2016.

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  1. Thajocoth

    Thajocoth

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    I have never written a privacy policy before. Unity Analytics is enabled in my game, so I'd like to know how to convey in my privacy policy whatever information I need to convey about Unity Analytics.

    I have selected the option that I suspect some of my users might be under 13, which means adhering to COPPA. There's local save data (PlayerPrefs), Unity Ads, Unity In-App Purchasing, and Unity Analytics. There are no log in screens of any kind.

    I'm a programmer, not a writer, so I'm not accustomed to this part. I've never done anything on the production level before. This is my first draft, but I figure it likely needs work:

    -----

    <GameName>Privacy.txt

    <GameName> save data is stored locally on your device and is never uploaded.
    There are no user accounts to log in to and no interactions with other players.

    Ads, in-app purchasing, and analytics are services that I'm using that have been provided by Unity.

    I have informed Unity that there is the possibility that children under the age of 13 may choose to play this game.
    Unity's services adhere to the Children's Online Privacy and Protection Act (COPPA).
    The Unity Ads service will not select ads that are inappropriate for children under the age of 13 to view.
    Unity's privacy policy can be found here:
    https://unity3d.com/legal/privacy-policy

    Some more information regarding Unity Analytics and the Children's Online Privacy and Protection Act:
    http://forum.unity3d.com/threads/age-designation.326930/

    I will update this policy immediately if there are any changes.

    -----

    Am I doing this at least halfway correctly? I can't compile & run a privacy policy...
     
  2. marc_tanenbaum

    marc_tanenbaum

    Unity Technologies

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    Hey @Thajocoth !

    Really appreciate your use of Unity Analytics. Unfortunately, this is something we really, really can't help you with. Legal policies like Terms of Service are beyond our ability to even hint at, since anything we advise could (by it's very nature) someday involve us in a legal dispute. Our advice is always to consult a lawyer for legal advice.

    I wish I could be more explicit, and I wish you the best of luck with your game.
     
  3. Thajocoth

    Thajocoth

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    I don't have any money for a lawyer... I had thought that it became possible to self-publish without already having any wealth.

    It's really surprising that you can't advise people on how using your services effects their privacy policy. If I could afford a lawyer, and I told her "I'm using these services in my game & really have absolutely no idea what they might really be looking at", I don't see how her knowledge of law could possibly cause her to translate that into "The policy needs to say X, Y, & Z." I'm merely guessing based on what little information I can find and what makes sense to me, which is part of why I posted it here for verification that I haven't assumed something that's false.

    If anything, having an "add this to your privacy policy if you're using this service" sort of thing should protect you more, as it would give exact wording and therefore keep people from writing something misinterpreted into their policies and then blaming you for being unclear. Non-programming languages are notorious for having the same things interpreted multiple different ways by different people.

    For example:

    "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."

    Does this mean that if N people download my game, that all users are sharing one unique ID? Or that there are N unique IDs for my game, one for each device it's downloaded on? I found this to be unclear.

    If I know exactly what is & isn't tracked by the three big black boxes I've enabled in my game (Unity Analytics, Unity Ads, & Unity In-App Purchasing), then I can at least make a list of tracked things, which should hopefully be enough transparency. ("Black boxes" means I can't see inside them. It's usually a reference to a programming style where people working on a system can't see how other systems work internally.)

    Another related question I can't seem to find any answer to is how the age selection for Unity Analytics effects the ads chosen by Unity Ads. I would assume that you'd be smart enough not to show inappropriate ads to an 8 yr old, but I really can't find any confirmation of this anywhere. I can't see samples to be sure until after I release the game, which is kinda late. Can I get any information on that topic?
     
    Last edited: Jul 21, 2016
    FlyingHighUp likes this.
  4. marc_tanenbaum

    marc_tanenbaum

    Unity Technologies

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    I'm genuinely sorry about that. It really boils down to "I'm not a lawyer, nor is anyone on our team." We simply can't dispense what amounts to legal advice as if our legal opinion is knowledgable.

    Maybe. I'll mention this at our next Customer Support synch-up and see what people say. Note, though, that in your very next paragraph you go on to demonstrate how even carefully crafted language can be re-interpreted. I think it's very doubtful that our company lawyers would agree to craft language and warrant that other organizations or individuals should rely upon it.

    Each user gets a unique ID on a per-game basis.

    It doesn't. The Ads dashboard has controls with which you can govern age appropriateness of Ads content.
     
    erika_d likes this.
  5. Thajocoth

    Thajocoth

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    Thanks, that's helpful information.
     
    erika_d likes this.
  6. LLTools_

    LLTools_

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    They threw the bomb in our hand and left us
     
  7. marc_tanenbaum

    marc_tanenbaum

    Unity Technologies

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    Truly sorry if it seems that way. We make a game engine. We're not lawyers. Running a game is a business, and there are aspects of a business that are simply outside our scope.
     
  8. technicat

    technicat

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  9. hippocoder

    hippocoder

    Digital Ape Moderator

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    OK seems correct, yeah.
     
    technicat likes this.
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