PRIVACY POLICY

As part of the ESRB Privacy Certified Program, we are subject to frequent audits of our Properties and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

Whenever you visit Properties that display the ESRB Privacy Certified certification seal, you may request information about:

• Whether a company uses cookies, tracks IP addresses or uses other passive means to collect information;
• Who, if anyone, is collecting your personal information and how will it be used;
• With whom, if anyone, will your personal information be shared;
• What choices you have with regard to the use of your personal information;
• How you can access and, if necessary, change the personal information a company collects and maintains;
• Whether and how information is collected from children under 13;
• How a company ensures data security, quality, and integrity;
• Where and how to ask questions or file complaints.

DISCLAIMER: Although ESRB Privacy Certified does not monitor non-English Properties, Activision makes all best efforts to ensure that non-English Properties adhere to applicable data collection guidance and principles set forth by ESRB Privacy Certified, including adherence to EU and other territorial regulations outside of the U.S.

If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact the ESRB Privacy Certified at: http://www.esrb.org/privacy/contact.aspx; or

ESRB
Attn: Privacy Certified Program
420 Lexington Ave, Suite 2240
New York, NY 10170
privacy@esrb.org

Information Provided by You
As set out in more detail in the following, Activision may collect Information from you when you: (A) create an Activision account with a Property; (B) use our Properties; (C) participate in sweepstakes, contests and promotions; (D) use Activision customer service; (E) choose to receive newsletters on products and services, receive marketing emails, and/or participate in surveys; (F) buy Activision services or products online; or (G) allow sharing through Social Media.

A. Creation of an Activision Account
Activision will collect certain Information from you when you register with a Property. Personal information collected during registration includes your first and last name, email address, username, and in specific cases, phone number. This personal information is combined with other Information such as your date of birth, country and information about your interests in and use of various products, programs and services and marketing preferences. Additionally, we collect and combine Information when you link a third party account (e.g., XBOX Live, PlayStation Network, Steam and Battle.net) to your Activision account, such as the username associated with you third party account, and the use of certain Properties may require you to link a third party account to your Activision account. 

B. Use of Our Properties
When you visit or use our Properties we collect, process and/or combine Information about your use of those Properties, such as websites you visited before and after you used a Property, browser type and language, IP address, hardware and software information, advertising ID, third party account information (e.g., the username associated with your XBOX Live, PlayStation Network, Steam or Battle.net account), gameplay data, purchase histories, and Social Media data. We use Cookies and/or similar technologies (collectively referred to as “Cookies”) to do this. In addition, we or our partners also use Cookies and advertising IDs to serve ads in our Properties. Please see our Cookie Policy for more details.

Activision collects, processes, and combines data such as your age, gender, interests, name, email address, gameplay, marketing preferences, customer service, and device-related information.

Activision also publicly displays certain Information about you, including third party account information and gameplay information, on the Properties. For example, your PlayStation username will be displayed on leaderboards if you are a top player in a certain Activision game, regardless of whether or not you have an Activision account. If you have synced a third party account with your Activision account, we may make your username available to be searched by other users if you have not opted out of this feature. You may unlink the third party account or prevent it from being searched at any time through your Activision profile settings.    

To provide fair gaming experience to all players, Activision uses anti-fraud technologies to prevent any cheating and bad behavior in our games.

C. Sweepstakes, Contests, and Promotions

When Activision runs contests or promotions on our Properties, we collect certain Information from participants such as their name, address, postal code, email address, phone number, age and/or date of birth, or other information or content submitted by you. We may also need to collect additional information in order for you to claim a prize. That Information will be combined with other account information and will be used and shared in accordance with this Privacy Policy.

D. Interact with Customer Service

In order to be able to provide you with customer service and assist you with resolving any issues you may have, Activision collects Information from you including your contact details, together with details of your customer service issue and its resolution.

E. Receive Newsletters on Products and Services, Receive Marketing Emails, and/or Surveys

Activision offers you the ability to receive newsletters or marketing periodically by email about our products and services. We also, from time to time, will send you surveys in order to improve player experience with our games. At any time, you can manage your preferences from your account settings and stop receiving further newsletters by unsubscribing from the link in the footer of each email we send to you. 

F. Mobile Advertising

Our mobile games include advertising for third party products and services. By accepting this Privacy Policy and downloading or continuing to play our mobile games, and unless you opt out of interest-based advertising as explained in our Cookie Policy, you consent to us and our advertising partners collecting, sharing and using information about you to show you relevant third party ads that might be of interest to you in our mobile games, and to improve advertising, targeting and measurement systems.

When you play our mobile games, we collect and share Information, including advertising IDs, non-personal identifiers and other information from your mobile device with advertising partners to enable the technical delivery of ads to your device. Our advertising partners may combine this Information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our mobile games or to improve the accuracy of their targeting and measurement systems. We recommend that you review our advertising partners’ privacy policies for more information, accessible in our Cookie Policy.

You can review your options to manage and opt-out of mobile advertising by (1) visiting your mobile device developer's website or reviewing your device manual. Most mobile device developers will tell you how you can manage the settings on your mobile device to opt out of and/or delete Cookies from your mobile device, or to limit the use of your advertising ID, reset your advertising ID, and/or opt out of targeted advertising; or(2) by visiting http://networkadvertising.org/managing/opt_out.asp and/or http://youronlinechoices.com, or if you are in the EU http://www.youronlinechoices.eu/, for choices to opt out of advertising. You can also click on the AdChoices logo within an advertisement (where available).

Please note: adjusting your preferences as described in this section does not mean you will no longer receive advertisements, it only means the ads you do see will be less relevant to your interests. We will also still use your device’s advertising ID to serve you with ads that may be less relevant to you; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).

G. Buy Activision Products or Services Online

Activision does not collect any credit card and/or billing information when you purchase products or services (such as digital content) online. However, you may be required to provide credit card and/or billing information to one of our third-party vendors in order to complete a purchase. We encourage you to review the privacy policy of our third-party vendors before providing them with your personal information, as their privacy practices may vary from ours. At the time of purchase, in specific cases, you also have the option to provide Information (such as your email address) to Activision for the purpose of sending you additional information or offers.

H. Social Media

You can interact with some Properties through social networking sites, such as Facebook and Twitter (or social media plug-ins and applications) ("Social Media"). When you interact with Activision and/or the Properties through Social Media you acknowledge that we access your Information, solely in accordance with your Social Media privacy settings, and use it to tailor content, marketing, and improve and adjust user experience relating to Activision Properties, as well as (1) give you exclusive content; (2) personalize your online experience with us within and outside our Properties; and (3) contact you in accordance with applicable marketing preferences through Social Media, including through providing tailored marketing, or directly by sending you the latest news, special offerings, and rewards.

When you post personal information publicly through the Properties, or on Social Media, it will be viewable by other users of these sites and we cannot prevent further use of the personal information by third parties. For more information about how your Social Media uses and protects your personal information, please refer to their privacy policies and terms of use.

Information Provided by Other Sources
We may also obtain Information, such as contact details (for example, name and email address), country, IP address, purchase histories, marketing preferences, cookie information, hardware and software information and other technical information about you from other sources, such as our affiliates, Social Media, our vendors (for example, event ticket providers and merchandise vendors), or partners (for example, advertisers, media partners or platform providers (e.g., Microsoft, Sony, Nintendo and Steam)), and combine that Information with Information we have collected from or about you. We only collect Information from other sources where they have confirmed to us they are legally entitled to share it with us.

We use Cookies to provide and support our Properties and each of the uses outlined and described above. Please see our Cookie Policy for more information.

Your Choices About Information Provided by You

If you do not want to provide Activision with personal information, then you can choose not to provide it. Please note that if you choose not to provide us with personal information, we may not always be able to provide you with the relevant Activision product or service that you want. For example, without providing an email address, you will not be able to create an Activision account.

Your Choices About Information Provided by Third Parties

You may be able to control how third parties collect and share your Information by changing your preferences or opting out of collection directly with those third parties. Before disclosing Information to third parties, we recommend you check their respective privacy policies for further details.

Your Choices About Activision Using Your Information

You can exercise choices over how Activision uses your personal information and update your preferences at any time:

• to remove yourself from individual contests or promotions, or from receiving email marketing or newsletters from Activision, simply click the unsubscribe link in the email or access your account from https://www.activision.com/ and edit your email marketing preferences. You will need your password to access your account;
• to disable selected Cookies from collecting information relating to the effectiveness of advertising campaigns or analytics data and from serving you with personalized advertising on our Properties or third party properties please see our Cookie Policy.

If you opt-out of receiving email marketing communications from us, please note we may still contact you occasionally about the status of your account, such as to inform you that your account may be expiring, or for other service related information.

If you are a user located in the European Economic Area (“EEA”) and would like to know more about your rights in connection with your personal information, please see the Users in the EEA section below.

Vendors and Partners
Vendors and partners provide goods and services (for example, platform providers, media partners, event ticket providers, merchandise vendors, survey providers, billing, consumer services support, consultancy, information technology hardware and software) to Activision in order to support, operate and develop the Properties and to deliver marketing communications on our behalf. Vendors use your Information to execute, deliver and/or from time to time improve the services they provide. We do not share Information with vendors to use for their own direct marketing purposes or any other purpose other than those set out in this section without your consent.

Law
We will disclose your Information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability. 

This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Legal Rights
We will disclose your Information where necessary for the purpose of exercising, establishing or defending our legal rights.  For example, we will review your gameplay, communications, and other account information in order to investigate allegations of cheating, hacking or any other breach or alleged breach of any applicable Terms of Use or this Privacy Policy and disclose your personal information, including communications, to our legal advisors, consultants and law enforcement or other government officials.

Protecting Others
We disclose your Information with third parties where we believe this is necessary to protect the rights, property or safety of any person. For example, we disclose Information relating to an online account if we in good faith believe the user of that account is using it in ways that are harmful to others (e.g. making inappropriate contact with minors).

Sale of Our Business or Assets
Separately, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Activision's customer information including Information and communications may be transferred to our successor or assign.

Activision takes a range of security measures designed to protect your personal information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information like user generated content, leaderboard rankings, and scores, etc.). We also take steps to ensure that the personal information collected is protected from misuse and alteration. In addition, we request vendors who process personal information on our behalf to themselves take a range of security measures designed to help protect your personal information. However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any personal information collected, stored or used by us or our vendors cannot therefore be guaranteed.

If for any reason you wish to view, correct, or update personal information collected about you, or if you want to deactivate your Activision account, simply access your Activision account through https://www.activision.com/ or another product or service as applicable and edit your personal information. You will need your password to access your personal account. You may also send us an email asking us to deactivate your account at privacy@activision.com.

If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, you can send your request to us using the contact details set out in the Contacting Us section below.

Retention Period

We delete your personal information which we process for the performance of the contract or based on your consent in case you terminate your contract with us, deactivate your Activision account, withdraw your consent or where you request us to delete your personal information in accordance with this Privacy Policy. As an exception, we will not delete your personal information where we still have a legitimate interest to use your personal information. For example, we may still retain your Information to resolve disputes, enforce our Terms of Use or other user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. In any case, we will not retain or use your personal information longer than necessary for the purposes outlined in this Privacy Policy. Due to technical reasons, residual copies of Information that has been removed from your account and/or the Properties may remain in our backup systems for approximately one month.

Legal Basis for Processing Your Personal Information

We only process your personal information where we can rely on legal grounds to do so. We process your personal information for the purposes set out below.

Performance of the Services

We process your personal information for the performance of our services, to provide or support of our products, or for any other feature you request or enable. This includes, for example, using your personal information to:

• administer your Activision Account;
• provide contests or promotions in which you have enrolled;
• support purchases you make;
• support game functionality;
• provide global customer service; or
• provide a fair gaming experience by using anti-fraud technologies such as bans or blocks of accounts.

Consent

We process your personal information based on your consent. This includes, for example, providing:

• newsletters, direct e-mails and surveys about our Properties;
• targeted ads in our mobile games; and
• certain other marketing features.

Legitimate Interest

We process your personal information where we have a legitimate interest to do so. This includes, for example, processing:

• to provide you with requested customer service or technical support;
• to debug and improve our current and future Properties;
• in order to give you exclusive content, personalize your online experience with us and contact you in accordance with applicable marketing preferences; and
• for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.

Legal Obligation

We process your personal information for compliance with a legal obligation to which we are subject.  

Your Rights to Your Personal Information

You have the following rights in addition to your rights to view, correct, update, or request the deletion of your personal information as set out in detail in the Accessing Information section above. To access or delete your personal information, you can also make a request here.

You may object to the processing of your personal information based on a legitimate interest on grounds relating to your particular situation. You may, in particular, control the extent to which we market to you and you have the right to request that we stop sending you marketing messages at any time. You can use the methods described in the Accessing Information section above.

In certain circumstances, you can request that we transfer personal information that you have provided to us. You can send your request to us here.

Where we rely on your consent in order to process your personal information, you have the right to withdraw such consent to further use of your personal information at any time. You can use the methods described in the Accessing Information section above to update your marketing preferences.

For each of the rights described above, you can also send your request to us by using the contact details set out in the Contacting Us section above.

We hope that we can satisfy queries you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law occurred.

International Transfers

Your personal information will be transferred to and processed in the United States where many of our central databases operate or other countries where Activision group companies or vendors maintain facilities or business operations. We use European Commission approved contract clauses to protect your personal information. If you have questions, please contact us using the contact details set out in the Contacting Us section above.