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Unity Analytics and GDPR

Discussion in 'Unity Analytics' started by wwcolter, Jan 17, 2018.

  1. mmvlad

    mmvlad

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    @Swah

    same here. And with it I guess bye bye Unity inapps. Did you find any good replacement or you don’t use them?
     
  2. Swah

    Swah

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    We do use unity IAP for one product, but I'm not sure my sales in europe are worth changing system entirely, especially if unity analytics eventually becomes GDPR compliant. For that single app I might just disable sales in Europe for a few months, until Unity gets things figured out.
     
    sandbaydev likes this.
  3. yogergames

    yogergames

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    I got the following information in an email from a Unity representative yesterday:

    "It is not possible to prevent Unity Analytics from collecting personal data as long as Analytics is enabled. Removing Analytics will stop its collection."

    As far as I can tell it makes it impossible to use IAPs for users in EU. On the other hand the following can be seen on https://unity3d.com/legal/gdpr

    "What does opting-out of Unity Analytics mean for a player?
    Players will be able to opt-out of Unity Analytics on a per-game basis. If a player chooses to opt-out, Unity Analytics will no longer optimize game experiences based on their in-game behaviors.

    How will Unity allow players to opt-out of Analytics?
    Similar to Unity Ads, you will be able to give players the ability to opt-out of data collection via a plug-in that you can integrate into your games. Integrating the plug-in will only be necessary if you are not using Unity Ads. It will be provided prior to May 25, 2018."
     
  4. CDF

    CDF

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    The plugin isn't available yet right? I can't seem to find a download link.

    Getting pretty close to May 25th now...
     
    SoerenL and sandbaydev like this.
  5. coshea

    coshea

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    "If a game developer or publisher enables Unity Ads or Unity Analytics for their game, we collect data such as device type, country, device language, in-game behavior and purchases, IP address, Apple’s Advertising Identifier (IDFA), and Google Play advertising ID"

    my understanding as a non-lawyer from everything I've read online, that you need to have players opt-IN to allow analytics if this is the PII above, not opt-OUT as Unity have suggested.

    Also players have the right to request the information being held on them and have their records deleted. Unity haven't addressed those issues yet.

    A week until GDPR rules come into play and Unity have been very vague in answering questions at the beginning of this thread and still no sdk. How long are they giving developers to update their games?
     
    sandbaydev likes this.
  6. yogergames

    yogergames

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    Yes, that's true, consent should be retrieved before collecting anything.

    But is there a way around IAPs for EU? On their GDPR page they state

    "Similar to Unity Ads, you will be able to give players the ability to opt-out of data collection via a plug-in that you can integrate into your games. Integrating the plug-in will only be necessary if you are not using Unity Ads"

    So if all IAP users also include Unity ads and disable collection of PII it will automatically be disabled for Analytics as well?
     
    SoerenL and sandbaydev like this.
  7. Swah

    Swah

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    Thanks for the additional information regarding yogergames. My current hope is that Unity removes the requirement to use Unity Analytics for using their IAP services.
     
    sandbaydev likes this.
  8. sandbaydev

    sandbaydev

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    Where is the plugin to integrate?
     
    SoerenL likes this.
  9. Leonid

    Leonid

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    Hello guys! Maybe you could just add some settings on server side of Analytics for developers to be able to disable personal data collection for certain app (as a temporary solution).
     
    sandbaydev likes this.
  10. sandbaydev

    sandbaydev

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    Exactly.

    I have trouble understanding how it's possible to "store data" but when asked to "hey, how about not store that data?" it seems it's impossible.

    It's a database in the web. :)

    Somebody at Unity should be able to define what information you store in a database. :)
     
  11. antifuzz

    antifuzz

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    Feb 22, 2013
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    I emailed Unity directly asking if we need to update Unity Analytics to be compliant (even if we don't use Unity Ads) and just received this response:

    "yes, it will be necessary to update the Analytics plug-in in order to be GDPR compliant, regardless of Unity Ads usage. Second, this update will be released soon; in other words, late this week or early next week."

    Hooray! I'm really looking forward to updating ten apps - some still on Unity 4... erpp...
     
    Leonid, sandbaydev and MorenoBralts like this.
  12. DevLev

    DevLev

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    If the game is completely free and has no ads, but uses "Unity Analytics", then the GDPR does not apply to it?
     
    Shawn_Flanagan likes this.
  13. Shawn_Flanagan

    Shawn_Flanagan

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    That's exactly what I've been trying to figure out. I'm in the same boat; my Unity apps are free, have no ads or IAPs, but we do use Unity Analytics' Standard Events for basic info. I'm not sure if that's enough personal data to require GDPR compliance, but I would rather be too cautious than assume my apps are fine the way they are.
     
  14. sandbaydev

    sandbaydev

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    Whether game is free or not doesn't matter.

    If it uses Unity Analytics, it means it's collecting personal information for Unity, and they use it for business.

    It seems "Unity will release an analytics plugin that you can use to update your game" is the thing to wait for.
     
    chribbe likes this.
  15. DevLev

    DevLev

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    What if?: The game is made on Unity. The game does not use Unity Analytics. The game is published in some store (Google Play/App Store/Microsoft Store / etc.), which provides Analytics (for example: many shops show the number of downloads, location of downloads (country), time in the game, etc. This analyst even can not be shut down). Because of this, the game will fall under the GDPR?
     
  16. chribbe

    chribbe

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    Does this mean that all games* made with Unity needs to be updated during next week? Or am i missing something?

    * except games made with unity pro not using analytics, has HW-stats turned off and not using any IAP
     
  17. IvyKun

    IvyKun

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    I think that means every game made with unity analytics or unity ads enabled needs to be updated next week yeah.

    I would loooove a server solution so I can just enter unity analytics dashboard and disable them until I have time to update my games, because I have a few T_T
     
  18. CDF

    CDF

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    I assume Performance Reporting falls under this GDPR thing as well right?
     
  19. migrax

    migrax

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    Would it be possible to build your own IAP plugin so there would be no need for Unity Analytics to remain enabled?
     
  20. Mattias-Wargren

    Mattias-Wargren

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    Shawn_Flanagan and MorenoBralts like this.
  21. migrax

    migrax

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    What do you guys think about such thing. The whole point of analytics is representativeness of the collected data. I'd think that if UA is now allowed to collect only data from those who have given their consent it would mean that the data is skewed in unknown way and thus not very useful anyway.
     
  22. Shawn_Flanagan

    Shawn_Flanagan

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  23. MoribitoMT

    MoribitoMT

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    I am confused about Unity InAppPurchases ?

    Lets say we have only Unity IAP and no Ads at al ? IAP enables Unity Analytics and we cannot turn off

    1. Will there be a dialog for IAP only for using analytics ?
    2. What if user refuses to accept analytics, IAP will not work anymore ?
    3. We cannot force user to accept analytics, what will we do then ?
     
    migrax likes this.
  24. IvyKun

    IvyKun

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    Seeing that 25th is too close I think I'm just going to un-publish all my games from Europe until I can get everything updated. And probably just update to remove analytics and in-apps, as I'm not getting much from in-apps anyway.

    It's ridiculous that we should have everything updated and ready by 25th and every SDK out there is still not ready for this...
     
  25. MoribitoMT

    MoribitoMT

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    %100 agreed. AdMob not ready, Google not ready, Unity not ready... I am asking simple IAP question above, no answer at all.

    I will also unpublish apps from Europe too, this will not cover GDPR compliance but it will reduce the risks greatly..
     
  26. JDestrier

    JDestrier

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    Agreed, these guys had 2 years to get ready....

    @MoribitoMT off topic here, but on a side note, AdMob announced last week (yay!) a solution without the need to update the SDK. You still need to build your own consent form, but if the user opts-out, you can call non-personalized ads by adding (AddExtra ("npa", "1") to the ad request in unity:
    AdRequest request = new AdRequest.Builder ().AddExtra ("npa", "1").Build ();
     
    MoribitoMT likes this.
  27. MoribitoMT

    MoribitoMT

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    I know that,

    However Non-Pers ads have still require consent for cookies, and users have right to deny it, which allows users to play the game for free without ads. This is why AdMob Consent SDK comes with 3 options "Pers, Non-Pers, Ad-Free". Crazy stuff going on here..
     
  28. pep_dj

    pep_dj

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    Yes, it's is crazy, but I think it's not true. Why do you say users have right to deny ads for free?
     
  29. MoribitoMT

    MoribitoMT

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  30. JDestrier

    JDestrier

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    oh man, this is nuts...
    The only way left now is to A/B test the consent form to stay alive
     
  31. pep_dj

    pep_dj

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  32. MoribitoMT

    MoribitoMT

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  33. pep_dj

    pep_dj

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    Currently everybody is talking about GDPR with no idea, and forums are full of misunderstandings. GDPR and E-privacy(cookie law) are different laws. AdMob requires explicit consent to show personalized ads to comply with GDPR law, and soft consent to show non-personalized ads to comply the e-privacy law.

    If you chose to only show non-personalized ads to eu users, you only need a alert dialog to notify the use of Id-device, example in https://www.cookiechoices.org.

    Also, nobody forces you to give the app for free. If users don't want to see ads, you can force them to pay, or don't use the app.

    You said that "You cannot give user negative consequences, if they not consent". I know people is saying that in some forums but... any official source saying it?
     
  34. HT-OAludden

    HT-OAludden

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    Correct me if I'm wrong, but I think this (§3.1. Free / freely given) does?
     
  35. pep_dj

    pep_dj

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    Thank your for the link. I understand that you cannot force your users to give you their data, but you are not forced to let them use your app for free. "Give me your data or pay to use my app" is a real choice, and they are free to consent or not.
     
  36. MoribitoMT

    MoribitoMT

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    What if we do not paid model? Do we have to have 2 versions of app for every game?
     
  37. HT-OAludden

    HT-OAludden

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    Acctually, I don't think so.
    however, I think this is only in the case of Personalized ads (based on the geo location data they're asking for). That said, I believe you're right about a cookie notification being enough to serve non-personalized ads, I certainly hope so atleast :s
     
  38. pep_dj

    pep_dj

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    If it's not ok to say the user: "Or accept personalized ads, or pay, or not use my app", then it should not be ok to say the user "Pay, or not use my app". But "Pay, or not use my app" is like any paid app works.
     
  39. pep_dj

    pep_dj

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    You don't need to have 2 versions, you can have an in-app-purchase for removing ads.

    To sum up:
    It's not ok to say: "Or personalized ads, or don't use my app", so we can give the users these options:
    1. Or personalized ads, or don't personalized ads (showing a "cookie" usage message).
    2. Or personalized ads, or remove them (paying, like any other paid app).
    3. Combining all above: Or personalized ads, or don't personalized, or remove them (like AdMob Consent SDK)
    Please correct me if I'm wrong
     
    MoribitoMT likes this.
  40. MoribitoMT

    MoribitoMT

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    But Unity IAP uses Unity Analytics, and you cannot turn off analytics, it is must feature to use IAP. For analytics you will need personalized consent?

    It is so confusing?
     
  41. HT-OAludden

    HT-OAludden

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    There are two passages in the Working Party 29 document that makes me say this

    If I've interpreted these wrong, that'd be great, but right now I'm rather overly cautious
     
  42. pep_dj

    pep_dj

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    You can use IAP without using official Unity plugin. But if you are using Unity plugin (like me), they said there will be another plugin available this week to allow users to turn off analytics.
     
    MoribitoMT likes this.
  43. pep_dj

    pep_dj

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    I think here the law is a bit confusing. What if I say in the consent message: "This app costs $1, but if you see personalized ads, it's free for you!". Here there is no negative consequences for don't showing personalized ads, the app costs $1 for everyone, but if you see personalized ads, then there is an advantage.
     
  44. MoribitoMT

    MoribitoMT

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    One more thing, you cannot force users to pay in app purchase, it is aganist apple polivies, directly rejected. IAP should never prevent game play.

    So you cannot put an option like give consent or remove ads to play game.
     
  45. pep_dj

    pep_dj

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    But we are not forcing them to pay, they have an alternative: see ads.

    We are forcing them to see ads? No, they can buy (GDPR complaint).
    We are forcing them to buy? No, the can see ads (Apple complaint).
     
  46. MoribitoMT

    MoribitoMT

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    Yes it seems like that, but I am %99 sure apple will reject apps with this style, we will see how apple will react to this.
     
  47. jashan

    jashan

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    Analytics only is what's relevant for us. I'm currently considering disabling Unity Analytics until this is all clear.

    @matthewpruitt @Cecilie or @marc_tanenbaum Do you have any news on this?
     
  48. pep_dj

    pep_dj

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  49. MoribitoMT

    MoribitoMT

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    Finally.

    It seems like native android / ios implementation. Will there be Unity version of it I wonder ?
     
  50. pep_dj

    pep_dj

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    I am an Android developer, so I can create a Unity plugin for Android. Any iOS developer here that can make a plugin for iOS?
     
    MoribitoMT likes this.