Take-Two Interactive Software Privacy Policy

Last Update: 25 March 2021

Take-Two Interactive Software, Inc., and its subsidiaries that make up the Take-Two Interactive group of companies (collectively "Take-Two," “we,” “us” and “our”), is a leading developer, publisher and marketer of interactive entertainment. This Privacy Policy explains our data practices for the products and services that we offer to consumers through Apple Arcade (collectively the "Services").

Scope of this Policy and Who We Are

Take-Two includes labels and divisions that are part of Take-Two, such as Rockstar Games, 2K, Private Division, Social Point, and Ghost Story Games. This Privacy Policy applies to all Take-Two labels and divisions (https://www.take2games.com/labels/) for Services through Apple Arcade. Please read this Privacy Policy carefully. The Services also are subject to our Limited Software Warranty and License Agreement (“EULA”), Terms of Service, and any other policies included in our Services.

  • 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.

If you contact us or use our services outside of Apple Arcade, our standard Privacy Policy will apply.

Information We Collect and Our Lawful Bases for Processing

The types of information that we collect depend on how you use the Services and interact with us. We do not collect any personal information from you through these Services. The Services collect gameplay information to manage your settings, game progress, and in-game activity or achievements. This gameplay information is stored on your device. If you choose to connect with Game Center or use iCloud to sync your game progress across devices, gameplay information will be sent to Apple. We do not receive or store this gameplay information on our servers.

—Lawful Basis to Process in Certain Locations To the extent that the information collected through the Services is considered personal information, we collect, use, and otherwise process your information when we have a lawful basis, as follows:

  • 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.

  • 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.

How We Use Information

To the extent that we process your personal information through the Services, we use the information we collect from and about you within Take-Two for a variety of business purposes including to: provide the Services; and provide support and security for our products. Apple lets you post information about your game activity to Game Center to share with others. If you use these features, Apple’s privacy policies and terms govern your actions on Game Center 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.

When We Share Information

To the extent that we process your personal information through the Services, we share your information with our vendors that perform support and other services in connection with the Services; and with third parties for legal and safety purposes, in connection with the sale or transfer of a business or asset, or for use in aggregate or anonymous form.

—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 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.

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

  • 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.

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 or apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services 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.

Contact Us

If you have questions or concerns about this Privacy Policy or our practices, contact our Privacy Policy Administrator at 646-536-2842; via email at [email protected]; or by postal mail at Take-Two Interactive, Attn: Privacy Policy Administrator, 110 W 44th Street, New York, NY 10036 USA. If you are located in the UK, EU, EEA or Switzerland, please indicate that in your email, letter, or phone call; you may also have the right to complain to a data protection authority. 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 us, go to https://www.take2games.com/data-request. We do not respond to support requests or other non-privacy related correspondence at this point of contact.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to ensure that you are aware of 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.