Take-Two Interactive Software Privacy Policy

Last Update: 15 December 2022

Take-Two Interactive Software, Inc., and its subsidiaries that make up the Take-Two group of companies ("Take-Two", "we", "us" or "our"), is a leading developer, publisher and marketer of interactive entertainment. This Privacy Policy explains data practices for the products, services, and websites provided by the Take-Two entities and labels listed here (“Services”). Please read this Privacy Policy carefully, and keep in mind that our practices and the data we collect may differ depending on how you use the Services.  The Services are also subject to any other terms and policies included in our Services. This Privacy Policy supplements privacy disclosures provided with your software product and from your platform manufacturer.  

This Privacy Policy does not apply to personal information collected from job applicants. Please see our job applicant privacy policy available here.

Notice at Collection of Personal Information: Please see the Categories of Information Collected and How We Use Personal Information and Our Legal Grounds sections for an overview of what information we collect, and why, and the Data Rights section for information about how to exercise your privacy rights, including opting out of the sale or sharing of your personal information.

Categories of Information Collected

The type of information we collect depends on how you use the Services. Generally, we collect the following information:

  • Identifiers / Contact Information: Name, user name, gamertag, postal and email address, phone number, unique IDs, mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address

  • Protected Characteristics: Age and gender

  • Commercial Information: Purchase and usage history and preferences, including gameplay information

  • Billing Information: Payment information (credit / debit card information) and shipping address

  • Internet / Electronic Activity: Web / app browsing and gameplay information related to the Services and information about your online interaction(s) with the Services or our advertising

  • Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls)

  • Profile Inferences: Inferences made from your information and web activity to help create a personalized profile so we can identify goods and services that may be of interest

  • Audio / Visual Information: Account photos, images, and avatars, audio information via chat features and functionality, and gameplay recordings and video footage (such as when you participate in playtesting)

  • Sensitive Information: Precise location information (if you allow the Services to collect your location), account credentials (user name and password), and contents of communications via chat features and functionality.

How We Use Information and Our Legal Grounds

We use the information we collect within Take-Two as follows, pursuant to various legal bases:

  • Business Purposes: Provide the Services and support; fulfill orders and requests; improve the Services and our business; develop new products and services; enhance your experience on the Services; protect the security for our users, employees, facilities, and Services; and develop internal marketing and demographic studies

  • Commercial Purposes: Market and advertise our and our business partners’ products and services; send you promotional materials; and administer promotional activities or events

We also use your information as permitted by law.

Sources of Information We Collect

How we obtain information depends on how you use the Services. For example, we collect information:

  • you provide directly to us, such as when you set up an account, sign-up for marketing, or contact us

  • about the games you play (automatically)

  • from third-party platforms, such as when you play our games or access our Services with third-party accounts

  • automatically, including through cookies and similar tracking technologies

  • from third parties, such as advertising networks, business partners, third party information providers, and other players

—Information You Provide

You provide us with information when you use the Services, such as when you: 

  • create an account or use the Services

  • subscribe to marketing 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 or share features

  • participate in events, contests, promotions, surveys, or playtesting

  • participate in an activity where you 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, password, platform ID, software products played, survey data, geolocation, and the systems or platforms you play on. We combine this information across devices that you use. 

—Gameplay Information

When you use the Services, we automatically receive information about your gameplay. Gameplay information includes your platform ID or gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device IDs, other platform / device information, and other information and statistics regarding your use of the Services. We collect gameplay information even if you do not register for the Services. We may combine gameplay information with other information we have about you.

—Platform, Gaming, and Social Networking Information

We collect information when you access our Services with third-party platform accounts, such as a gaming platform account, gaming network service account, or social networking service account. When you access our Services in this way, 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 the Services or 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.

—Cookies and Similar Technologies

We use cookies, web beacons, Flash cookies, Internet log files, software developments kits and similar tracking technologies to improve and maintain the functionality of our Services; enhance security and fraud prevention; and provide you with targeted advertising. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications, and Data section provides additional information about our use of cookies and similar technologies and your ability to manage cookies. You may also use the cookie preference tool, where available, or visit the Cookie Policy posted on the Service for more information.

—Information from Third Parties

We receive information from third parties to update the information that we collect about you. We may receive information from public databases, platform manufacturers, analytics providers, game developers, and other business partners and Take-Two group of companies involved in providing the Services to you, that includes demographic information and information about your interests.  We may collect publicly available information, including from social media, to protect our users, employees, facilities, and Services, and to aid investigations. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on the Services or an individual sends us a direct message.

When We Share Information

As detailed below, we share your information with:

  • vendors that perform support and other services for us

  • Take-Two group members

  • advertising service providers and partners

  • other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission)

  • other users, such as when you participate in open communities or events, or information published on leaderboards

In the last 12 months, Take-Two has sold and/or shared unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences with third-party advertising providers to enable us to provide personalized advertising to you and others like you. We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent’s) consent.

—Vendors

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.

—Advertising 

We use Take-Two and third-party advertising to support our Services, such as ad networks, data exchanges, traffic management service providers, social networks, and marketing analytics service providers. These providers use cookies and similar tracking technologies (see Cookies and Similar Technologies above) to collect information about your device and your Service use. This information, along with information that we share with them, enables us or our providers to recognize you or your device and to serve ads to you or your device and measure the effectiveness of those ads. This includes Identifiers / Contact Information, Internet / Electronic Activity, Device and Usage Data, and Profile Inferences.

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 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 on our Services; and (5) helps us improve our Services.

You can learn more about managing how we and our providers use your information in the Manage Your Account, Communications, and Data section; and, as applicable for the Service, by using our cookie preference tool, where available, or visiting the Cookie Policy posted on the Service.

—Third Parties

We share your information with third parties as described in this Privacy Policy, including as follows:

  • 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, users 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.

  • As Disclosed to You: We may share your information as disclosed to you at the time of collection.

—Other Users

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 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.  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.

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 platform account with us, we may display your in-game achievements along with your account name.

Public Postings

If you share personal information, post an image or video, or provide other content in public forums such as on a message board, chat room, comment field, or profile page, other people can view, collect, and use that information. If your user name or ID contains your name, your name will be publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may be able to identify you, use the information to send you messages, or copy any of the images, video, or content you have shared. There is no expectation of privacy or confidentiality on any of these public forums. Please do not share your personal information in public forums or in your user name or ID. You are responsible for any information or content you publicly post using our Services. 

Data Rights

Depending on your location, you may have certain rights over your personal information, including the right to:

  • Request access to or a copy of your personal information

  • Request deletion of your personal information

  • Request correction or modification of your personal information

  • Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes

  • Withdraw consent, if processing is based on consent

  • Opt-out of the sale or sharing of your personal information (including targeted advertising)

  • Opt-in/out of financial incentives

  • Limit the use and disclosure of your sensitive personal information

You can make a data rights request in relation to your personal information here. We will respond to data requests within a month. We may take steps to verify your identity before we can respond to your request. 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 privacy authority. A list of privacy authorities is available here. Alternatively, if you wish to make a data request or appeal a data request decision, please contact Take-Two using the details provided in the Contact Us section.

To opt out, please click on the Do Not Sell or Share My Personal Information 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. We will not discriminate against you for exercising any of these rights.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

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; email unsubscribe and deletion tools; and opting out of interest-based ads.

More information about how to manage your label-specific account and communications is available here.

—Service Accounts

You can manage how we use your personal information and the communications that you receive from us through the account, communications, and privacy settings in your Services account.

—Email Unsubscribe

You can unsubscribe from marketing emails from Take-Two or a specific label or division by using the unsubscribe link provided in the email. 

—Interest-Based Ads

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/. For visitors from the UK, EU, EEA or Switzerland, visit Your Online Choices at http://www.youronlinechoices.eu/

Data Retention

We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to delete 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. 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 terms and policies, 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.

Children’s Privacy

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.

Data Security

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.

International Transfers

We and our vendors and partners may process, transfer, and store information about you in connection with the Services in the United States and other countries that may not have privacy 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 Data Rights or Contact Us section. 

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, platform manufacturers, and other partners, including: (i) the terms that accompanied your purchase; (ii) terms applicable to online Services; (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.

Contact Us

If you have questions about this Privacy Policy, please use https://www.take2games.com/data-request to contact our Data Protection Officer. You may also contact us or our Data Protection Officer by mail at the addresses below. Please identify your location in your message. You may also have the right to complain to a privacy authority. You may also contact us by email at [email protected].

Country

Address

Non-European Countries

Take-Two Interactive Software, Inc.

110 W 44th Street, New York, NY 10036 USA,

Attn: Privacy Policy Administrator

UK, EU, EEA, or Switzerland

(“European Countries”)

Take Two Interactive Software Europe Limited

Take-Two House

30 Cleveland Street, London W1T 4JD, UK

Attn: Privacy Policy Administrator

For purposes of privacy laws, the data controller of your personal information is Take-Two Interactive Software, Inc. and – for users in the UK, EU, EEA or Switzerland – Take Two Interactive Software Europe Limited. Depending on the Services, our labels and divisions may be considered data controllers, either together with Take-Two Interactive or by themselves. Data controller and representative information and contact details are listed here. References in this Privacy Policy to Take-Two should be interpreted as references to the applicable Take-Two entity identified as the controller of personal information for the particular Services you are using.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.