Published on January 15, 2019
WELCOME TO UBISOFT SERVICES.
This Policy and the certification seal shown on the Services confirm that Ubisoft is a member in good standing of ESRB's Privacy Certified Program. ESRB's Privacy Certified Program is designed to ensure that our Services’ information disclosure practices are responsible and appropriate. As part of this privacy program, we are subject to frequent audits of our Services and other enforcement and accountability mechanisms administered independently by the ESRB.
Table of content :
- When does Ubisoft collect your personal information?
- What personal information does Ubisoft collect?
- How does Ubisoft use my personal data ?
- For how long does Ubisoft keep my personal data ?
- With whom does Ubisoft share my personal data ?
- Does Ubisoft make my personal information public? Who can see my personal information?
- What are my rights ?
1. When does Ubisoft collect your personal information?
Ubisoft collects and processes your personal information at different times when you interact with our Services. Generally, personal information is collected when:
- (a) you use a Service,
- (b) you create an Account,
- (c) you make a purchase within our Services,
- (d) you create user generated content,
- (e) you watch advertisements within our Services,
- (f) you sign up for a newsletter,
- (g) you contact Ubisoft customer service and during technical support sessions,
- (h) you enter into a contest or sweepstakes,
- (i) you chat with other users of the Services,
- (j) you participate in a beta or otherwise download a patch or a demo, or
- (k) you share or otherwise contribute to our social media channels or other community websites.
Whatever the activity may be, and in accordance with the minimization principle stated in the GDPR, we will only collect personal information to the extent necessary to provide you with the Services and fulfil your requests.
2. What personal information does Ubisoft collect?
2.1 When you use Ubisoft services2.1.1 While Browsing Ubisoft websites
IP addresses.Ubisoft also collects Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Other passively collected information.While browsing our sites, Ubisoft may, on its own, or with the help of third party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviors and use of our Services. Ubisoft collects such information to better adapt our Services to users’ interests, and for a better quality of our Services. The information collected may contain the following, without limitation: device unique identity, including MAC address, console, mobile, tablet and console unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.2.1.2 Registering on a Ubisoft service
To access certain Services, you will need a Ubisoft Account. During the creation of your Account, we will ask your user name, password, email address, date of birth (or age) and country of origin. This information is mandatory to create an Account. On other Services, Ubisoft may ask you additional personal information relevant to the Service such as your phone number, home address, or geo-location information (for example, you will be asked your home address when purchasing a product within our online shop, in order for Ubisoft to deliver the product to your home address).2.1.3 Creating a Ubisoft account
By creating a Ubisoft Account, you agree to receive newsletter or adverts about Ubisoft products, services, and sales. You can unsubscribe at any time by:
- (a) clicking the unsubscribe link contained in all Ubisoft email marketing messages;
- (b) changing your contact preferences on your Ubisoft account page at https://account.ubisoft.com; or
- (c) contacting http://support.ubi.com or email@example.com with your unsubscribe request.
- (d) sending your unsubscribe request to Ubisoft, Inc. Attn: Privacy Rights Administrator c/o Legal Department, 625 Third Street San Francisco, 94107 CA, USA
Ubisoft may offer you the opportunity to participate in online surveys, questionnaires, contests and sweepstakes. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in contests, sweepstakes, surveys and questionnaires, your personal data may be processed to allow you to participate, or to inform you of sales on a specific product, or to give you some information about new products or services, and for internal statistical use.2.1.6 Interacting on forums
Whenever you participate or interact with other users on a forum, Ubisoft collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.2.1.7 Adverts
You can find a list of our partners whose analytic tools and ad serving technologies are used in our Services at https://legal.ubi.com/cookies/. Ubisoft makes its best efforts to provide you with the links to our partners’ privacy policies, and when available, instructions to opt-out from their services.2.1.8 Social media and other third parties’ platforms
Ubisoft may work with trusted marketing partners to bring you more useful and interesting advertising content on our Services and on third party sites and services. Provided that you ticked the “Share my information with select parties” box during your subscription or in your Ubisoft Account settings, we may do this by sharing or matching the personal information you have provided us on the Services with the information (which may include personal information) you have provided third party marketing partners.
As explained above in the cookies section, we may share some information via cookies and other technologies. To learn more about our trusted marketing partners or opt-out of this sharing, please consult https://legal.ubi.com/cookies/.
2.2 Whenever you play Ubisoft games2.2.1 Registering when activating a Ubisoft game
If you play Ubisoft games on a third-party console, your ID for this console will be disclosed to Ubisoft, in order to let Ubisoft create your Ubisoft Account. You must have a Ubisoft Account in order to access certain online features. From your console, Ubisoft receives your username and your password, your e-mail address, your date of birth, and your country of residence.2.2.2 Creation of user generated content
Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by Ubisoft; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). Please exercise caution: Ubisoft is not liable for any negative consequences linked to your disclosure of User-generated content.
Ubisoft, may on ios games, integrate Apple’s TrueDepth API to use your facial characteristics in-game through the camera of your iphone (for example: changing your face for an in-game character face). No face data nor any other biometric data is stored or sent to Ubisoft servers or any third party. If you want to opt-out please consult https://legal.ubi.com/cookies/.2.2.3 In-game data collection
2.3 Online payment
3. How does Ubisoft use my personal data?
3.1 Legal basis for your personal data collection and processing
Ubisoft processes your personal data, wherever necessary:
- - To provide you with the Services (creation of your Ubisoft account, bug detection, fighting fraud, online payment…etc.)
- - To offer the best possible experience to users, and improve the Services (in-game data analytics…etc). It is in Ubisoft’s legitimate interest to process your data for these purposes.
- - To provide you with supplementary services (custom content…etc.). In such case, Ubisoft systematically requires your consent before processing your personal data for this purpose.
DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA. OUR PRIVACY POLICIES AND PROCEDURES ARE "AS IS" AND UBISOFT MAKES NO REPRESENTATIONS AS TO THE FITNESS FOR A PARTICULAR PURPOSE OR MERCHANTABILITY.
4. For how long does Ubisoft keep my personal data ?
5. With whom does Ubisoft share my personal information?
Ubisoft does not disclose your personal data to any third party without your prior consent.
5.1 Sharing your personal data with Ubisoft affiliated companies
5.2 Sharing your personal data with third parties
5.3 Sharing your personal data with governmental authorities
In accordance with relevant laws, Ubisoft may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for identification, challenging or enforcing legal rights against any individual that may potentially jeopardise to Ubisoft or any other Ubisoft user’s rights.
5.4 Sharing your personal data in case of mergers
In the unlikely event Ubisoft’s business activities or shares are transferred partly or totally to any third party, such third parties may access your personal data. In this case, Ubisoft may also allow your personal data to be transferred to the acquiring third party.
5.5 Transfers of personal data to third countries
Please be aware that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or Ubisoft partners, located in third countries such as, but not limited to, United States, Canada and China. A list of Ubisoft affiliated companies is available at http://www.ubisoftgroup.com/en-US/about_ubisoft/world_presence/world_presence.aspx. Some personal data recipients are located in countries that are not considered as ensuring an adequate protection level according to the EU Commission. In such case, Ubisoft uses the strict framework of the EU Commission’s approved standard contractual clauses, which are available on the EU Commission website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_fr/), or by request at firstname.lastname@example.org.
5.6 Business Information
For practical reasons, we treat Personal Information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal Information submitted to us in a business capacity (e.g. resumes) may be shared with third parties as described at the time of collection.
6. Does Ubisoft make my personal information public? Who can see my personal information?
Ubisoft Services may offer a public profile feature (“Public Profile”) that allows you to publish information, including personal information, to the public Internet. Other than as stated on the applicable Public Profile site, the information you upload or input to your Public Profile will default to the privacy level you choose at sign-in, and you can choose to change the privacy settings at any time. By default, certain aspects of the Public Profile are set to “public”. Those aspects of the Public Profile that are designated as “public” will be visible to everyone, potentially including people not registered within the Ubisoft environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.
Unless stated specifically to the contrary in a given Service, our Services are not intended for children, and Ubisoft will not request any Personal Information from children. For games that are not directed at children but nonetheless likely to appeal to younger players, we take additional steps to limit access to these Services on age grounds, and limit data collection for underage players to only what is necessary to support the internal operations of the Service.
In certain jurisdictions, for we may allow a child to register for specific Services with parental approval. In these circumstances, we will take additional steps to protect the child’s privacy, by notifying the parent about our information practices with regard to children, and asking for consent before processing their child’s personal information. Parents may delete their child's account, change their child's privacy settings, or access and modify their child’s personal data at any time by contacting customer support at support.ubi.com.
In all cases, use of the Services by Children must take place under the responsibility of their parents or legal guardians and any use of the Services is assumed to have been validated by them. AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, UBISOFT DECLINES ANY RESPONSIBILITY REGARDING ANY ACTIVITIES WHICH MAY BE CONDUCTED BY CHILDREN WITHOUT THE PERMISSION OF THEIR PARENTS OR LEGAL GUARDIANS.[JN70]
IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU GIVE YOUR PERMISSION FOR YOUR CHILD TO REGISTER FOR ONE OR OTHER OF THE SERVICES, YOU THEREBY AGREE TO THE TERMS RELATING TO USE OF THE SERVICES BY YOUR CHILD.
8. What are my rights?
In accordance with GDPR, you have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by Ubisoft, as well as the right of data portability. You can exercise these rights by writing to Ubisoft customer support, via the following website : http://support.ubi.com. Ubisoft will answer your request within a month following the receipt of your demand. In accordance with GDPR, Ubisoft reserves the right to extend this delay up to three months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (cookies, behavioural advertising…etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing. You may also address any complaint to the national supervisory authority of your country.
Do not Track: Ubisoft does not currently respond to Do Not Track (DNT) settings in your browser.
Your California Privacy Rights: The following applies solely to California residents who have an established business relationship with Ubisoft. If we collect Personal Information from you, we may make the Personal Information available to third parties for their marketing and promotional purposes with your consent. If you decide that you do not want us to share Personal Information from your Ubisoft account with these companies for their marketing and promotional purposes, please send an e-mail to email@example.com. In this email, state that you would like Ubisoft to not share your Personal Information with third parties for their marketing purposes. Your opt-out request will be processed within thirty (30) days of the date of which we receive it.
You can also write us at the address below:
Ubisoft, Inc. Attn: Privacy Rights Administrator c/o Legal Department
625 Third Street San Francisco, 94107 CA, USA
Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it. Ubisoft is a licensee of the ESRB's Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB by email at: http://www.esrb.org/privacy/contact.jsp or by mail at the address below:
Attn: VP, Privacy Certified Program
420 Lexington Ave, Suite 2240
New York, NY 10170