Scope of this Policy and Who We Are
Take Two Interactive Software Europe Limited is the data controller responsible for information for Services offered by Take-Two Interactive, Rockstar Games, 2K, Private Division, or Ghost Story Games to individuals in the United Kingdom (UK), European Union (EU), European Economic Area (EEA), or Switzerland, which it offers from the UK.
Social Point S.L. is the data controller responsible for information for Services offered by Social Point, which it offers from Spain.
Take-Two Interactive: https://www.take2games.com/applicantprivacypolicy/
Rockstar Games: https://www.rockstargames.com/careers-privacy
Information We Collect and Our Lawful Bases for Processing
You provide us with information directly, such as when you set up an account with us. We also collect information about you and your activity when you use our Services – whether through gaming consoles, computers, mobile devices, in-game applications, software platforms, third party social or gaming networks. We may use online tracking, such as cookies and similar technology, to collect information, when you share in-game content with friends, or connect to our Services, and we collect information from third parties (such as advertising networks and external business partners).
The types of information that we collect depend on how you use the Services and interact with us. You can control the personal information we collect from you unless we need it for the requested activity (e.g., to provide the Services you’ve requested or purchased, to confirm who you are, or to participate in an event). We will let you know when information is necessary.
Information You Provide
You provide us with information when you use the Services, such as when you:
create an account, or register for or use the Services;
subscribe to newsletters and communications;
comment on our message boards, forums, chat rooms, feeds, sites, or other Services;
purchase or redeem one of our products or services, including physical items, virtual items, virtual currency, or add-ons;
download, install, or access demos, programs, or other software;
contact us for support or other purposes;
use our email / share features;
participate in events, contests, promotions, or surveys; or
participate in an activity where you can provide, or need to provide, your information.
Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, hardware configuration, console ID, software products played, survey data, IP address, geolocation, and the systems you play on. We combine this information across computers or other devices that you use.
When you use the Services on hardware connected to the Internet, Take-Two receives information about your gameplay even if you are not specifically notified at the time or do not take any actions to actively give us this information. Gameplay information includes your console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device ID, other console / device information, and other information and statistics regarding your Service use. We collect gameplay information even if you do not register for the Services and we may collect gameplay information while you are offline. Offline gameplay information is transmitted to Take-Two when you next connect to the Internet. We may combine gameplay information with other information we have about you.
—Console, Gaming and Social Networking Information
We collect information when you use third-party platforms like a gaming console account, gaming network service account, or social networking service account to connect to or engage with our Services. When you use these third-party platforms or link your Take-Two account, the third-party platforms provide us with information about you. For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.
—Information from Third Parties
We receive information from third parties to update the information that we collect about you. For example, we receive information from public databases, console manufacturers, analytics providers, game developers, and other business partners that includes demographic information and information about your interests. We obtain information from social media and other publicly available sources, which we may use to better understand our users or to seek intelligence about breaches of our Terms of Service. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on our message boards, forums, chat rooms, or other Services, or an individual sends us a direct message, for example, about an alleged breach of our Terms of Service.
—Lawful Basis to Process in Certain Locations
We collect, use, and otherwise process your information when we have a lawful basis, as follows:
Consent: We ask you for consent to collect or use your personal information for specific purposes, such as when we want to send you emails about special offers or competitions, or if you decide to link your Take-Two account with a third-party service.
Contract Performance: We process your personal information when we need to perform and manage a contract with you, such as our Terms of Service, or to take steps at your request before we contract with you, such as to complete transactions with you and to allow you to play our games online.
Legal Requirement: We process your personal information when required by law.
Legitimate Interest: We process your personal information when necessary for our, or others', legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.
Cookies and Similar Technology
We may use flash cookies, also known as "local shared objects." You can clear flash cookies already on your device by adjusting the flash local storage setting on your device to zero. You may also prevent entities from placing flash cookies on your device by adjusting your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com.
A web beacon is an electronic image or tag that helps us deliver cookies, count users who have visited certain pages or viewed certain advertisements or mailings, and conduct analytics for our Services and communications.
—Internet Log Files
We may collect Internet log files when you use the Services. These log files can include IP addresses, MAC addresses or other device IDs, depending on your network configuration. Depending on the Service you use or the activity you engage in, we associate these log files with your information.
How We Use Information
We also use your information within Take-Two for commercial purposes, including: send you and similar consumers direct marketing and online / social media advertising from Take-Two and our business partners, including use of demographic information; for other purposes identified when you provide your information; or otherwise with your permission. We may further use your information as permitted by law.
If you participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as your user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites. If you participate in tournaments or other online game events, we must publicly post your information. We also use automated means to monitor gameplay to ensure that you and others use our Services in accordance with applicable policies, including our EULA and Terms of Service. If we find that you have breached our Terms of Service or other applicable policies, this could lead to your temporary or permanent exclusion from the Services.
We use information we collect from and about you for business purposes including to:
Provide the Services;
Fulfill product orders and other requests, respond to your questions, and communicate with you;
Enhance your experience on the Services, including to recognize you, maintain your preferences and settings, and link to your third-party console, gaming, and social networking platforms;
Provide technical and other support;
Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve our software, content, internal marketing, support, and Services;
Conduct internal marketing and demographic studies;
Analyze our users, in combination with other data, to assess our user base and target marketing at other similar groups;
Address issues with the Services or other business needs;
To protect the security or integrity of the Services and our business such as by protecting against and preventing violation of our EULA and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure; and
Interact on your behalf with the third-party console, gaming and social networking platforms you connect with our Services.
We use information we collect from and about you for commercial purposes, including to:
Provide you and other users like you with customized content on the Services, targeted offers and advertising on the Services, via email and text message, or on other sites, mobile applications, or social media on behalf of Take-Two or our business partners; and
Contact you with information, newsletters, and promotional material.
We also use information we collect from and about you to:
Participate in other processing that we inform you about when you provide your information or when you consent to such processing; and
As permitted by law.
We use the information we collect within the Take-Two Interactive group of companies including our labels and divisions Rockstar Games, 2K, Private Division, Social Point, and Ghost Story Games.
If you use certain Services, such as the Rockstar Games Social Club or 2K Account, we may automatically enter you into contests based on your membership or use of the Services. Check www.rockstargames.com/socialclub/events frequently for details regarding contests.
Even if you do not register for the Services, we publish gameplay boards and multiplayer match records that contain information based on your use of the Services, such as your user name or ID, when they are essential components of the Services that we offer you and others. We post certain game statistics publicly, but we do not post information that we know directly identifies you (like your real name or email address) unless you provide that information for this use. Like other gameplay statistic services, your game activity, leaderboards, and multiplayer match information may appear nested in the Services or third-party webpages.
Some third-party services also let you post information about your game activity to their sites to share with others. If you use these features, those third-party services’ privacy policies and terms govern your actions on those sites and the information that those services collect.
If you breach our Terms of Service or other applicable policies, we may temporarily or permanently exclude you from the Services. If you have violated our policies by creating certain user generated content, we may also temporarily or permanently limit your ability to make new user generated content.
We combine information collected through various Services and display it publicly, including on our Services, in our games, or in multiplayer game lobbies. For example, if you link your game console account with us, we may display your in-game achievements along with your account name.
When We Share Information
We use vendors to perform services on our behalf. These vendors provide business, professional or technical support to us, help us operate our business and Services, or administer activities in connection with our business and the Services on our behalf. These vendors are not permitted to use or share your personal information for their own or a third party’s commercial purposes.
We (and sometimes our providers) collect or share this information when you use our Services, click on a site or an ad, or launch one of our games or other mobile applications. This information: (1) allows us to accurately and properly pay for ads placed on our behalf (e.g., an ad that led you to purchase or download one of our games) and get paid when you see an ad on our Services; (2) helps prevent you from repeatedly seeing the same ads; (3) helps select and display targeted ads or other content on your computer or device (such as on a site or social networking service you are visiting or a mobile application you are using) that may be of particular interest to you; (4) helps with measuring and analyzing the effectiveness of our ads, popularity of content, and traffic in our Services; and (5) helps us improve our Services.
Collaborative Relationships: When we offer services or promotions in collaboration with a third party who will receive your information for its own use, we will inform you of that at the time of collection and you may choose whether to participate in the offering.
Legal & Safety: We may share your information to protect the security of our Services, servers, network systems, databases, and business and in connection with an investigation of fraud, intellectual property infringements, interference with our rights, property or users, or other activity that is illegal or may expose you or us to legal liability, including as required or requested by law enforcement or other government officials. We also may share your information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that it is necessary to protect our rights, investigate, or enforce our policies, terms, combat fraud, or comply with a judicial proceeding, court order, or legal process served on Take-Two. We also may share your information when we have reason to believe it is necessary to investigate or enforce our policies, terms, or other legal document or contract related to the Services or rights of a third-party.
Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. We may disclose information about you and transfer that information to another entity as part of a potential or actual acquisition or merger of Take-Two or any of our assets. If we bring or are defending a reorganization, bankruptcy, or similar event, such information may be considered our asset and sold or transferred to third parties.
Aggregate or Anonymous Information: We may share aggregate or anonymous information with third parties for their marketing or analytics uses. This information cannot be used to identify you.
As Disclosed to You: We may share your information as disclosed to you at the time of collection.
Manage Your Account, Communications, and Data
We provide several options for you to manage your Service account, communications you receive from us, and how we use your information. These include through the settings in your Service account; utilizing email unsubscribe and deletion tools; opting out of interest-based ads; and, depending on your location, making a data request or exercising your right to object to our use of your personal information. This can include, in some countries, a right to object to our use of your data. Additional information about California user rights are available in the Your California Privacy Rights section below.
You can manage how we use your personal information and the communications that you receive from us by logging in to your Service account and using its account and privacy settings.
If you have subscribed to a marketing or newsletter list from Take-Two, you can unsubscribe from that list when you receive a marketing or newsletter email from a specific label or division by using the unsubscribe link that is provided in the email.
On your mobile device, you may adjust your privacy and advertising settings to control whether you want to receive advertising based on your interests. To opt out from the use of your online activities for interest-based activities by participating providers, please visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://www.aboutads.info/ to select the applicable networks. For visitors from the UK, EU, EEA or Switzerland, visit Your Online Choices at http://www.youronlinechoices.eu/.
To delete your Rockstar Games Social Club account or, depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the personal information collected about you by Rockstar, sign in to your Social Club account, go to http://rsg.ms/account, and follow the instructions. We will respond to data requests within 30 days. To the extent these rights apply to you, they may be limited in some situations – for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a data protection authority. Alternatively, if you do not have access to your Social Club account and wish to make a request, please contact Take-Two using the details provided in the Contact Us section below.
If you are unable to log in to your Social Club account, or you do not have access to your Social Club account, and wish to delete your Social Club account, please email [email protected] from the same email account you used to join Social Club, include your Social Club nickname in the message, and include "Delete Account" in the subject line.
As described in the How We Use Information section above, when you use certain features your activity is public. Even if you delete your account or data, some activity information may still appear, including on certain gameplay boards including those hosted by third parties, such as console manufacturers (and copies hosted on Social Club).
To make a data request and depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the personal information collected about you by 2K, go to https://2kgam.es/datarequests. We will respond to data requests within 30 days. To the extent these rights apply to you, they may be limited in some situations – for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a data protection authority. Alternatively, if you wish to make a data request, please contact Take-Two using the details provided in the Contact Us section below.
To delete your 2K Account, sign in to your 2K Account, go to https://support.2k.com/hc/en-us/requests/new, and follow the instructions. If you are unable to log in to your 2K Account and wish to delete your 2K Account, please email [email protected] from the same email account you used to register your 2K Account with “Delete 2K Account” in the subject line.
To make a data request and depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the information collected about you by Private Division, go to https://pvtdi.vision/datarequests. We will respond to data requests within 30 days. To the extent these rights apply to you, they may be limited in some situations – for example when we are under a legal requirement or have a compelling interest to process your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a data protection authority. Alternatively, if you wish to make a data request, please contact Take-Two using the details in the Contact Us section provided below.
To unsubscribe from Social Point’s marketing or newsletter list, please email [email protected] from the same email account you used to sign up to that list with "Unsubscribe" in the subject line.
To make a data request and depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the personal information collected about you by Social Point, please do the following:
Go to the settings section in any Social Point game application;
Tap on Support;
Tap on any topic;
Tap again on any topic;
You should now see a “contact us” text in the top right-hand side of the screen, tap on this;
Provide us the details of the data subject right you wish to exercise.
We will respond to data requests within 30 days. To the extent these rights apply to you, they may be limited in some situations – for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a data protection authority. Alternatively, if you wish to make a data request, please contact Take-Two using the details provided in the Contact Us section below.
—Ghost Story Games
To make a data request and depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the personal information collected about you by Ghost Story Games, go to https://www.ghoststorygames.com/privacy-data-requests/. We will respond to data requests within 30 days. To the extent these rights apply to you, they may be limited in some situations – for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a data protection authority. Alternatively, if you wish to make a data request please contact Take-Two using the details provided in the Contact Us section below.
Your California Privacy Rights
This section provides information for California residents. Take-Two may require proof of California residency before responding to requests made under this section.
Categories of Information Collected
This section describes the types of personal information that Take-Two collects, uses, discloses, and may sell (as described more fully below). We discuss the business and commercial purposes for collecting this information in the How We Use Information section above. We categorize this personal information as follows:
Identifiers/Contact Information: Identifiers, including your real name, postal and email address, phone number, unique identifiers, location information, characteristics of protected classifications under California or federal law, and IP address.
Commercial Information: Your purchase and usage history and preferences.
Internet/Electronic Activity: Your web/app browsing and gameplay information related to the Services and information related to your online interaction(s) with the Services or our advertising.
Profile Inferences: The inferences that we draw from your information and web activity to help create a personalized profile so we can better identify goods and services that may be of interest.
Categories of Information Sold
In the last 12 months, as defined by California law, Take-Two has sold unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences to enable us to provide personalized advertising to you and others like you. We do not sell personal information about persons that we know are under the age of 16 without their (or depending on age, their parent’s) consent.
Categories of Information Disclosed
In the last 12 months, Take-Two has disclosed each of the categories of personal information described above (e.g., Identifier/Contact Information, Commercial Information, Internet/Electronic Activity, and Profile Inferences) for a business or commercial purpose.
To make an access or deletion request, please contact the applicable label as identified in the Manage Your Account, Communications, and Data section above. Alternatively, contact us at [email protected]. We may take steps to verify your identity before we can respond to your request.
Access Request. You may make up to two requests per year for information as to:
The categories of personal information that we’ve collected and sold about you, or shared for a business or commercial purpose with our service providers;
The sources from which we’ve collected such personal information;
The third parties with whom we’ve shared that personal information and to whom we’ve sold that information;
The business or commercial purpose for collecting or selling that personal information; and
The specific pieces of personal information we’ve collected about you.
Deletion Request. You may request that we delete the personal information that we’ve collected from or about you, although there are some reasons we will need to retain information, such as to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to maintain for internal purposes, to comply with a legal obligation, or to exercise our rights.
We will respond to your access and deletion requests within 45 days, unless we require additional time, in which case we will let you know.
Opt-Out Request. You have the right to opt out of Take-Two’s sale of your personal information to third parties for their commercial purposes. This means that if you opt out, going forward, we will not share your personal information with such third parties to use for such purposes unless you later direct us to do so.
To opt out, please click on the Do Not Sell My Info link on our site footer (and available here) and follow the instructions on that page. To opt out of online personalized advertising more broadly, please see the opt-out options identified in the Manage Your Account, Communications, and Data section above.
We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to cancel your account or request that we no longer use your personal information to provide Services to you, contact us as identified in the Manage Your Account, Communications, and Data section above. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal information, including your email address and log-in credentials, and you may no longer be able to access your account. We will notify you before we delete your account information so that you have the opportunity to keep your account active. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our EULA or Terms of Service, administer our services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services, after which we will take steps to delete or archive your personal information.
Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages—including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent’s permission to collect personal information from children. If we become aware that a child has provided personal information without a parent’s permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.
We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.
We and our vendors may process, transfer, and store information about you in connection with the Services in the United States and other countries that may not have data protection laws equivalent to the country where you reside. We take steps to apply appropriate safeguards when we transfer that information.
When your information is in another country, it may be accessed by the courts, law enforcement, and national security authorities pursuant to the laws of that country. If you reside in the UK, EU, EEA or Switzerland, we rely on Standard Contractual Clauses and/or other approved legal mechanisms to transfer personal information from the UK, EU, EEA or Switzerland to countries located outside of these locations (as applicable). To request a copy of such Standard Contractual Clauses, if applicable, please make a data request as provided under the Manage Your Account, Communications, and Data section above.
Other Take-Two Terms, Third-Party Terms, and Links to Other Sites
Use of our services and products may be subject to other terms and disclosures provided by us, console manufacturers, and other partners, including: (i) the EULA that accompanied your purchase; (ii) our Terms of Service; (iii) other terms and disclosures made available to you by us or third parties. We are not responsible for practices on third-party sites that may be linked to the Services.
—In-Game Transactions and Reseller / Store