Take-Two Interactive Children’s Privacy Policy

Last Update: May 15, 2023

Take-Two and the Take-Two group of companies ("Take-Two", "we", "us" or "our"), are committed to protecting the privacy of children. Take-Two offers a wide variety products, services, and websites provided by the Take-Two entities and labels listed here (“Services”). Some of them are for adults, but others may be of interest to children. This Privacy Policy describes how we handle children’s personal information under applicable children’s privacy laws for our Services that are intended for children. For information about how we collect, use, disclose, and protect personal information in all other settings, please see Take-Two’s privacy policy.

How to Contact Us

If you have questions about the practices described in this Policy, please 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.

You may also contact us or our Data Protection Officer at the webform available here.

Information We Collect

The types of information we collect depends on how children use our Services. Children – and their parents – choose what information to provide to us, but some features of the Services will not work or will be limited if we lack certain information.

Account and Profile Information

We may allow parents to create accounts for their children. When parents create these accounts, we collect information as part of the account creation process. For example, we ask for the child’s email address, user ID or display name, region, and age. Other account or profile information may be optional, such as images and avatars.

—Gameplay Information

When children play our games, we automatically receive information about their gameplay, including game achievements, game scores and performance, platform / device information, and similar information.

—Platform, Gaming and Social Networking Information

Children who have consent from their parents may be able to connect or link a child’s Take-Two account with information from third-party platform accounts (e.g., gaming platform accounts, gaming network service accounts, or social networking service accounts). We may collect information from connected third-party accounts. The third-party platform may allow users to control what information is shared with us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

—Online Game Play and In-Game Chat

Children who have consent from their parents may participate in certain forms of online game play. These online features include multiplayer game play, leaderboard rankings, and tournaments, and other online game events.

Parents may be able to choose whether children can participate in in-game chat and messaging. If this feature is enabled, we collect the contents of those messages or chats.

—In-Game Purchases

Some of our Services allow users to earn and spend in-game virtual currency. If a child makes an in-game purchase, we collect information related to the purchase, such as virtual currency used, earned or purchased, and the items purchased. Parents who allow children to make real money purchases will be asked to provide certain payment information (credit / debit card information) and shipping address.

—User Generated Content

Children who have consent from their parents may be able to share in-game content (e.g., accessories and cosmetics). These creations may be saved to a child’s account and used in other gameplay modes.

—Online and Device Information

We automatically collect certain information about a child’s interactions with us, including web/app browsing information that is associated with an IP address, device ID, device type, software and hardware details, language settings, browser type and version, and operating system.

If a parent chooses to allow the Services to collect location information, we may also collect precise location information of the device a child uses to interact with us.

—Persistent Identifiers

We collect identifiers from users’ (including children’s) devices to help identify a computer, browser, or device. We use cookies, web beacons, Flash cookies, Internet log files, software developments kits and similar tracking technologies to improve and maintain the functionality of the Services that are available to children; and to enhance security and fraud prevention. The Parental Choices and Controls section provides additional information about our use of cookies and similar technologies and parents’ ability to manage cookies. Parents 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 also receive information from other individuals who use our Services. This may include information about children who have permission to post to our message boards, forums, or chat rooms, and are mentioned in these areas of our Services. We also may receive information about a child from an individual who sends us a direct message, for example, about an alleged breach of our Terms of Service.

How We Use Information

We use the information we collect from children within Take-Two for several reasons, including to:

  • Make certain Services available to children

  • Fulfill product orders and other requests

  • Communicate with and respond to parents’ questions

  • Allow parents to choose children’s preferences and settings, including connections with other users and links to third-party platform and gaming accounts

  • Provide technical and other support

  • Improve and protect our Services and users

  • Conduct advertising on the Services on behalf of Take-Two or our business partners

  • Contact children with information and promotional materials

  • Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners

  • Participate in other processing that we inform a parent about and when the parent provides consent to such processing

  • As permitted by law

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

  • 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 a child participates in open communities or events, or information is published on leaderboards

—Third Parties

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

  • Collaborative Relationships: When we offer services or promotions in collaboration with a third party who will receive a child’s information for its own use, we will inform a parent and obtain consent. 

  • Legal & Safety: We may share children’s information if permitted or required by law, for example, to protect the security of our Services; facilitate the investigation of a crime or threat to users or public safety; or comply with a judicial proceeding, court order, or legal process served on Take-Two.  We also may share children’s information when we have reason to believe it is necessary to take precautions against liability, including our liability under an agreement with 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 Permitted by a Parent: As appropriate with permission, we may share children’s information as disclosed to and allowed by a parent.

—Other Users

If a parent allows a child participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites.  If a child participates in tournaments or other online game events, we must publicly post the child’s information.

We publish gameplay boards and multiplayer match records that contain information based on a child’s use of the Services, such as user name or ID, when they are essential components of the Services that we offer to children.  Like other gameplay statistic services, a child’s game activity, leaderboards, and multiplayer match information may appear nested in the Services or third-party webpages.

Some third-party services also let users post information about game activity to their sites to share with others. If a parent permits a child to use these features, those third-party services’ privacy policies and terms govern the child’s actions on those sites and the information that those services collect.

We combine information collected through Services available to children and display it publicly, including on our Services, in our games, or in multiplayer game lobbies. For example, if a child links a game platform account with us, we may display the child’s in-game achievements and account name.

Public Postings

If a parent enables features that allow a child to 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 a child’s user name or ID contains the child’s name, the child’s name will be publicly available on leaderboards and elsewhere as described in this Children’s Privacy Policy. Users of such public forums may be able to identify the child, use the information to send the child messages, or copy any of the images, video, or content the child may have shared. There is no expectation of privacy or confidentiality on any of these public forums.

Parental Choices and Controls

Parents have certain rights over children’s personal information, including the right to:

  • Request access to or a copy of the child’s personal information

  • Request deletion of the child’s personal information

  • Request correction or modification of the child’s personal information

  • Be informed about the personal information we collect and/or process about the child, 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

We provide several options for parents to manage a child’s Service account, communications from us, and our use of children’s information. These include through the settings in a child’s Service account; email unsubscribe and deletion tools. A parent may also make a data rights request on behalf of a child here. We will take reasonable steps to verify a parent’s identity before we can respond to such requests.

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

—Service Accounts

Parents have the right to review or delete their child’s personal information. Parents can also tell us to stop collecting and using their children’s information. Deletion may mean that a child’s account will become inactive, or the child will lose access some or all of our Services.

Parents can manage how we use children’s personal information and the communications that they receive from us through the account, communications, and privacy settings in the child’s account overview page.

Changes to Children’s Privacy Policy

We reserve the right to make changes to this Children’s Privacy Policy. Please check back from time to time to review these changes. If we change this Children’s Privacy Policy in a material way, we will provide appropriate notice to parents and, as appropriate, provide additional choices regarding such change.