Privacy Policy

DATED 2020-10-18 · VERSION 20220601_rev01 · COMPARED WITH 20220501_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20220501_rev01 to 20220601_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 **Last Updated: October 18, 2020**
+Last Edit/Review: April 6, 2022
+Last Edit/Review: May 31, 2022
 ## 1\. Frequently Asked Questions (FAQs)
 These FAQs provide a handy entry point to our longer and more comprehensive Privacy Policy (see Section 2 below). They are intended to enhance rather than replace the important notices in the Privacy Policy, which governs our collection, use, storage, and sharing of the information that we collect or receive from you.
+### What's new as of April 6, 2022?
+### What's new as of May 31, 2022?
+On May 31, 2022, we made edits to add our Ziva Dynamics product to our privacy policy. We also made some formatting updates to our California Rights section.
 On April 6, 2022, we made edits to add our SyncSketch product to our privacy policy. We also made some edits to provide clarity around your choices under our Reflect Review Application. We updated our list of Third Party Ad Network Partners.
 On October 30, 2021, we made edits to reflect compliance with China's Personal Information Protection Law ("PIPL"). We updated information that may be collected and updated our Third Party Ad Network Partners.
 On August 2, 2021, we updated our Third Party Ad Network Partners. We also added information to add our Pixyz product to our privacy policy
 - Pixyz software: If you use Pixyz software, usage analytics will be collected to improve the application. The usage analytics may include, the execution date & time, the name of the product used (Plugin), the session number, the version of the product used, the algorithms/functions used, and UX/UI interactions. Cookies and choices concerning Unity Ads:
 - - Unity and others working on Unity's behalf may employ cookies and related technologies to store information on or read information from your browser or device. The technologies used for these purposes may include: (i) cookies; (ii) web beacons; (iii) tracking pixels; and/or (iv) local shared objects (also known as Flash cookies). To learn more, see our [Cookie Policy](https://unity3d.com/legal/cookie-policy).
     - Unity may collect information, including the App List, to provide personalized ads. To learn more, see our [Cookie Policy](https://unity3d.com/legal/cookie-policy).
     - Third-party advertisers (and the ad networks they use) who place ads within the Service may use cookies or related technologies to deliver ads. To learn more about the use of cookies and related technologies within the Service, see our [Cookie Policy](https://unity3d.com/legal/cookie-policy).
 - Reflect Review Information: We run our analytics in our Reflect Review Application. This includes analytics such as active session, session time, and in-app events. These analytics are used for performance and support. In certain regions, you may opt-out of such analytics through deselecting the "send optional analytics" button on the homescreen of the application.
+- Biometric Information: associated with our customers' storage of data they collect from you using our tools, such as Ziva's Face Trainer.
 - Other information: We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
 Unless we request it, we ask that you not send us, and you not disclose, any special category data or criminal offense data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the Unity website, the Services or otherwise to us.
 ## 4\. How We Use the Information We Collect or Receive
 ### Pixyz Services
 _Developers_: You can opt-out of Usage Analytics collection anytime, by simply changing the parameter inside the software settings.
 ### SyncSketch Services
+You can delete your account by following the instructions [here](https://support.syncsketch.com/how-do-i-delete-my-user-account). To request access to your information, please email privacy@syncsketch.com.
+You can delete your account by following the instructions [here](https://support.syncsketch.com/how-do-i-delete-my-user-account). To request access to your information, please email [privacy@syncsketch.com](mailto:privacy@syncsketch.com).
+### Ziva
+If you are a developer using our Ziva tools, and you would like to access or delete your Ziva account information, please email [DPO@unity3d.com](mailto:DPO@unity3d.com). If you are a data subject whose facial scan was collected by a Ziva customer, please reach out directly to the customer to delete or access your information.
 ## For services not listed
 Please email [DPO@unity3d.com](mailto:DPO@unity3d.com) to request access to or update your information. You can request that your account be deleted by emailing [DPO@unity3d.com](mailto:DPO@unity3d.com); however, certain financial recordkeeping information may be maintained in our systems because we have a legitimate legal and financial interest in maintaining such records.
 ### **Gameplayers viewing Unity Ads or Profiled in Unity Analytics or deltaDNA**
 ## 11\. Safeguards
 We employ a variety of measures to safeguard the collection, transmission, and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 ## 12\. Privacy Rights
+- _Please note that Unity has placed a new [California Notice of Rights](https://unity3d.com/legal/do-not-sell-my-personal-information) on its website to explain how California residents may exercise their privacy rights under the **California Consumer Privacy Act**. This notice is incorporated into this policy. Generally, under this new law, California residents have_
+    _Sharing with third parties for direct marketing purposes:_ California residents have the right to request the identity of any third parties to whom the resident's personal information was shared, if such sharing was to enable the third party's direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to [DPO@unity3d.com](mailto:DPO@unity3d.com) OR to opt-out of having your personal information shared with third parties for their direct marketing purposes, please email us at [DPO@unity3d.com](mailto:DPO@unity3d.com).
+- _Please note that Unity has placed a [California Notice of Rights](https://unity3d.com/legal/do-not-sell-my-personal-information) on its website to explain how California residents may exercise their privacy rights under the **California Consumer Privacy Act**. This notice is incorporated into this policy. Generally, under this law, California residents have_
 . _A right to transparent notice about the collection of your data;_
 . _A right to know what personal information Unity holds about you, including where we obtain it and the categories of third parties with whom we share it,_
 . _A right to request deletion of personal information in certain circumstances;_
 . _A right to opt-out of sales of personal information;_
 . _An ability to appoint a third party representative to assist you with exercising your rights and,_
     - _Please note Unity does not discriminate in its provision of services to you based on exercising your rights._
     - _Your requests to delete data is limited to data that Unity is not allowed to retain under the CCPA. Unity may retain data for certain purposes, including completing transactions for you or reasonably related to completing transactions for you, detecting security incidents, illegal activity and fraud, maintaining our systems, complying with applicable law and legal obligations, engaging in public or peer reviewed research provided we comply with applicable ethics and privacy laws related to such research, or enabling solely internal purposes such as financial recordkeeping._
     - _You may ask a third party representative to assist you in exercising your rights. Third parties may write to [DPO@unity3d.com](mailto:DPO@unity3d.com) to provide documentation of their right to act on your behalf. If you are a game player, we will not have a way to locate records about you outside of an app using Unity's software, but you may direct your reports to be sent to your representative once you have verified your identity inside of the app. Unity account holders may also send data reports obtained through your account directly to your representative. You need only to provide their email or mailing address instead of your own when ordering. For third party representatives writing in on behalf of Unity account holders, please provide the name and any signed documentation you may have to act on behalf of the account holder, or you may ask the account holder to write to us from their account email to provide us permission to transact with you directly. Unity reserves the right to take reasonable steps to verify the authenticity of identities and authorizations in compliance with applicable laws prior to making any disclosures._
     - _More information on your rights as a Californian and instructions on how to exercise them with Unity may be found [here](https://unity3d.com/legal/do-not-sell-my-personal-information)._
     - __You may view our CCPA Transparency Report at [https://unity3d.com/legal/privacy-report](https://unity3d.com/legal/privacy-report). This report provides details on our responses to requests to access, delete or opt-out under CCPA.__
+_Sharing with third parties for direct marketing purposes:_ California residents have the right to request the identity of any third parties to whom the resident's personal information was shared, if such sharing was to enable the third party's direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to [DPO@unity3d.com](mailto:DPO@unity3d.com) OR to opt-out of having your personal information shared with third parties for their direct marketing purposes, please email us at [DPO@unity3d.com](mailto:DPO@unity3d.com).
 - _How we respond to "Do Not Track" signals:_ We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information in our [Cookie Policy](https://unity3d.com/legal/cookie-policy) about how to prevent the delivery of targeted ads, and information in this policy about how to prevent Google Analytics and Twitter from collecting information. We do not, however, recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. To learn more about Do Not Track signals, you can visit [allaboutdnt.com](http://www.allaboutdnt.com/).
 If you are a European Union resident, the **General Data Protection Regulation** provides certain rights to you with respect to your personal data. Where Unity is a data controller, you have the following rights:
 - **Right to Access** - You have the right to request Unity provide you with a copy of your personal data.
 - **Right to Rectification (Correction)** - You have the right to request Unity to correct any information about you that you believe is incorrect. You also have the right to request Unity to complete information about you that you believe is incorrect.
 - Some of Unity's product features require access to your camera. While using these features we ask that you be aware of your surroundings and be considerate of others. Use of these features may result in cached images being saved to your device. In certain products, we may save your images to our cloud servers. You will be notified at the time of access if the images are being saved to our servers. Please keep your security features on your device up to date and securely dispose of your device when you change devices by clearing this information.
 - For more information on the Unity AR Companion App, which is one of our services that uses your camera, please see the App's [Supplemental Privacy Notice](https://unity3d.com/legal/supplemental-privacy-statement-unity-MARS).
 - You will have an opportunity to consent to camera access prior to Unity accessing your camera.
 ## 17\. Biometric Information
+Your use of these features may result in the collection of biometric information. Biometric information is any information based on an individual's biometric identifier used to identify an individual. Biometric information that may be collected depending on how you use Unity's products includes scans of an individual's hand or face geometry. For example, if you are using Unity AR Companion AP to scan a person's hand or face geometry, that may be considered to be collecting biometric information under Applicable Laws. At this time, Unity does not use these scans, but we do store the image in accordance with how you choose to store the data.
+Your use of certain features may result in the collection of biometric information. Biometric information is any information based on an individual's biometric identifier used to identify an individual. Biometric information that may be collected depending on how you use Unity's products includes scans of an individual's hand or face geometry. For example, if you are using Unity AR Companion AP to scan a person's hand or face geometry, that may be considered to be collecting biometric information under Applicable Laws. At this time, Unity does not use these scans, but we do store the image in accordance with how you choose to store the data.
 We use commercially reasonable organizational, technical, and administrative methods designed to protect biometric information within our organization.
 We retain biometric information for as long as needed or permitted in light of the purposes stated in this policy, unless a longer retention period is permitted or required by applicable law. For more information on the criteria used to determine our retention periods, please see the "Retention" section above.
 We will destroy or dispose of your biometric information as required by applicable law. For example, we may destroy electronic records of biometric information through such processes as overwriting magnetic media, degaussing, or physical destruction, and we may dispose of paper records by such processes as shredding or incineration.
+Please note you may need to make your request for deletion through Unity's customer as we do not directly collect your data and cannot likely locate your account without our customer's assistance.
 ## 18\. Contact Us:
 - [DPO@unity3d.com](mailto:DPO@unity3d.com)
 - Unity Technologies, 30 3rd Street, San Francisco, CA 94103 (United States contact)
 - Unity Technologies ApS, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark (European Union contact)
 - Unity Technologies, 39F, No. 501 Dongdaming Road Sinar Mas Center, Hongkou District, Shanghai, 200080, China