I just got an email from Blizzard with a reply. It's the longest email I've gotten to date.
I figured this situation requires an update. So, here's it is:
Greetings!
Your email has reached the data protection team at Blizzard Entertainment.
We take your privacy very seriously.
The following answers your questions and addresses your request for a copy of the data we hold which is connected to you.
Who is processing your data?
Blizzard Entertainment International, a division of Activision Blizzard International B.V., is the data controller for the processing of your personal data. We are a registered company located at
Prinses Beatrixlaan 582, WTC The Hague, Tower E, 6th Floor, 2595 BM The Hague, The Netherlands.
For the performance of certain games and platform services, your data may be controlled by Blizzard Entertainment, Inc. in the United States.
What information do we collect, and how long do we keep it?
We collect information from or about you in the following ways:
Information provided by you. Information provided by you when you create or update your account(s); when you are an esports player; while you use our social features and channels to communicate with others; when you use any of our services for purchases or financial transactions such as store purchases, in-game purchases, and/or prize processing; and while you are receiving customer service support.
Information we get or generate from your use of our games or services. We collect data related to: your game play and in-game activity, the services that you use and how you use them, and your devices and activities when you install or access our services.
Information collected from external sources. We may receive information about you and your activities from third parties when you link to external accounts (such as Facebook, PlayStation, XBOX or Twitch) and from advertisers or service providers about your experiences or interactions with them. We might also obtain information from public sites on the internet, such as Twitch, Instagram and YouTube, to mention a few.
We treat all information associated with your account to be personal information. Blizzard collects the following categories of data depending on which product(s) or service(s) you are interested in or interacting with. We usually retain data for only as long as necessary to provide you with products, services and an immersive entertainment experience. Exceptions are noted below.
ACCOUNT DATA - Player Account Data refers to information that is provided and generated when a player creates his or her account. Most of this data is available to the player by logging into his or her account and can be updated by the player in the account settings section.
Examples: Account name, BattleTag, name, email address, preferred language, date of birth, SMS number, home address, shipping address (on file), account balance, beta opt-in(s) and account links.
Who has access to this type of data? Operations, Game Teams, esports (if applicable), Customer Service, Publishing and Security.
CUSTOMER SERVICE - We also use the information we collect while assisting players through our customer support services to investigate and address players' concerns and monitor and improve our services. Information gathered or produced during support of our players is retained for up to 2 years to ensure that we address concerns and issues in the best way possible.
Examples: Issues raised, case history, restrictions history, contact details, customer service communications and account notes.
Who has access to this type of data? Most of the time, it's just Customer Service and Security, but occasionally Operations, Game Teams and Legal access this data.
SOCIAL DATA - Blizzard uses the information we collect from players' actions to enable communications between our players in multiple ways, such as chat, Forums and on-line gaming (e.g. Fireside Gatherings in Hearthstone).
Examples: Forum content (version, allocation, locale, time zone, access groups, game accounts, posts), Fireside Gatherings details, chat groups, chat logs, friend lists and profile information
Who has access to this type of data? Operations, Customer Service, Game Teams, Publishing and Security.
TRANSACTIONS - We collect transaction details related to the licensing and purchasing of our products and services, and also the contests and competitions we sponsor. Transaction data may be retained for up to 7 years (primarily for audit purposes).
Examples: Order details/history, subscriptions, chargebacks, refunds, gifts, payment detail, shipping details, prize awards and competition accreditation details.
Who has access to this type of data? Operations, Consumer Products (as applicable), Customer Service, Publishing and Security.
ACTIVITY DATA - When a player interacts with our services, we collect server logs. Server logs are routinely retained for 30–90 days.
Examples: IP address, access dates and times, crash records, cookies, activity region and internet service provider.
Who has access to this type of data? Operations, Game Teams, Customer Service and Security.
DEVICE DATA - We may collect information about the devices used to access our services.
Examples: Device ID, hardware models, operating systems and versions, software, file names and versions and unique device identifiers.
Who has access to this type of data? Operations, Game Teams and Security.
COMMUNICATIONS - Blizzard may use the information we collect from players or partners to communicate with our players about our current and upcoming products, services, promotions, studies, surveys, news, updates and events. Blizzard may also use this information to promote and process contests and sweepstakes, fulfill any related awards and serve you relevant ads and content about our services.
Examples: Name, email address, survey details, purchase/license history, activity history, email activity and phone device token.
Who has access to this type of data? Operations and Publishing.
ESPORTS PLAYER RECORDS/TOURNAMENT DATA - We gather information related to personal details, rankings, performance stats and team details to follow up on the career and performance of our competitors.
Examples: Contact method, legal guardian details, experience, rate history, rankings, performance stats, team details and player handle.
Who has access to this type of data? Esports and Operations.
ESPORTS REFERENCES/MISC. INFORMATION - We collect information from players who participate in our esports events to provide personalized care and assistance during competitions.
Examples: Dietary restrictions, food allergies and clothing sizes.
Who has access to this type of data? Operations and esports.
ESPORTS TRAVEL DATA - Our tournaments and competitions are hosted all over the world. Therefore, we collect pro-players' information needed for travel arrangements and assistance.
Examples: Passport and visa details, default airports and nationalities.
Who has access to this type of data? Operations and esports.
COLLEGIATE EDUCATION, EXPERIENCE INFORMATION. - This type of information is collected primarily from collegiate esports players to better manage our tournaments.
Examples: School name, transcript, collage major, GPA, company name, job title, Tespa Chapter and associated information.
Who has access to this type of data? Operations and esports.
LEGAL RECORDS - We keep records as support for any actual or anticipated legal matter.
Examples: Pro-Players' contract agreements and case files.
Who has access to this type of data? Operations and Security.
MEDIA INFORMATION – Media presence details of journalists and players that have an impact on our community.
Examples: Discord handle, Reddit handle, Twitch cheer, Twitch handle and Twitter handle.
Who has access to this type of data? Operations, esports and Publishing.
GAME DATA - Game data are generated while a player plays our games. We keep records of players' game licenses, progress, history, stats, in-game purchases and interactions with other players.
Who has access to this type of data? Operations, Game Teams, Customer Service, Publishing and Security.
Why do we process your data?
Blizzard collects and uses your data for the following purposes:
Gameplay Experience. Creating the well-designed, highly enjoyable entertainment experiences you can find within our epic games! This includes:
Progress and History
Examples of data used:
GAME DATA: Char stats, match history, quest in progress, etc.
In-game Social
Examples of data used:
GAME DATA: Guild information, in-game email, friends list, etc.
Unlocks
Examples of data used:
GAME DATA: Inventory items: collection of cards, gold, dust, armory, skills, etc.
Game Currency
Examples of data used:
GAME DATA: Earnings history, items a player can/has purchase(d): portraits, skins, heroes, cards, etc.
Esports Pro-Gaming Competitions and Broadcasting. We bring to you an official network of professional competitive gaming in many of our franchises. The production of these tournaments often required travel, lodging and nutrition. Many of these tournaments are broadcasted and require player-background information to facilitate a great viewer experience. Examples include:
Broadcasting & Production
Examples of data used:
PLAYER RECORDS/STATS: BattleTag, age, country, gender, name, nationality, player handle, professional team name, professional teammate name(s), tournament team name, tournament teammate name(s), tournament rank, tournament performance stats, tournament team rank
EDUCATION/EXPERIENCE INFORMATION: College major, GPA, school name, Tespa chapter, job title
INFLUENCER INFO: Facebook handle, Instagram handle, Twitch Channel, Twitter handle
Event Travel and Logistics
Examples of data used:
ACCOUNT DATA: Name, email address, age, parental information (if applicable), BattleTag, phone number, photo
REFERENCES/MISC. INFORMATION: Allergies, disabilities, medications and dietary restrictions
TRAVEL DATA: Passport details, visa details
PLAYER RECORDS/STATS: Rankings, performance stats, team details, player handle
Tournament Administration
Examples of data used:
ACCOUNT DATA: Name, email address, age, parental information (if applicable), BattleTag, phone number, photo
Media Information: Tespa ID, PSN account
Collegiate Esports. Whether your goal is to start a Tespa chapter on your campus or join an established gaming community, Tespa's support will level up your gaming experience.
Tespa Students
Examples of data used:
TESPA ACCOUNT: Chapter applications, chapters events, chapter meta data, username and password
ACCOUNT DATA: Name, email address, age, parental information (if applicable), BattleTag, phone number, photo
Player's Account, Parental Controls and Security. Players of most of our games use a Battle.net account to house assets, communicate with friends and learn about our games and services. Parents of our younger players may set parental controls to monitor and control their children's gaming.
Player's Account
Examples of data used:
ACCOUNT DATA: Name, email address, age, BattleTag
ACTIVITY DATA: IP address, login information
Parental Control
Examples of data used:
ACCOUNT DATA: Parental control email, child's account information
Business optimization and service development. We conduct troubleshooting, research, analysis and product and service development to provide you with the best gameplay experiences and services. This includes:
Analytics & Data Segmentation
Examples of data used:
ACCOUNT DATA: Blizzard account, country, third parties' IDs
ACTIVITY DATA: IP address
GAME DATA: Related players, chat records
Training & Development
Examples of data used:
ACCOUNT DATA: Name, phone number, country, home address
ACTIVITY DATA: IP address
GAME DATA: Character name
CUSTOMER SERVICE: Ticket issue description, account notes, Customer Service chat log
Reporting
Examples of data used:
ACCOUNT DATA: Account region, BattleTag
ACTIVITY DATA: IP address, preferred language
TRANSACTIONS: Game Consumable licenses
Global Customer Service. We provide you with personalized support to investigate and address any possible difficulty you might experience with our games, your account or your purchases. This includes:
Customer Service
Examples of data used:
ACCOUNT DATA: BattleTag, country, language, phone number/SMS number
ACTIVITY DATA: IP address, region, timestamp
GAME DATA: Game account, guild name, character name
CUSTOMER SERVICE: Account notes, chat records and case history
Forum Moderation
Examples of data used:
SOCIAL DATA: Forum posts
Business Operations. We process orders for our products, tournaments and services. This includes:
Store Purchase
Examples of data used:
ACCOUNT DATA: Email address, BattleTag, country, language, phone number, home address
ACTIVITY DATA: IP address
TRANSACTIONS: Invoices, refund details, subscriptions, licenses, payment details
Events Ticketing
Examples of data used:
ACCOUNT DATA: Email address, BattleTag, name, phone number, home address, phone number
Tournament Hosting
Examples of data used:
ACCOUNT DATA: Name, email address, phone number, address
ESPORTS DATA: Tournament Information, Tournament Organizer details
Social Features. We enable communications and experience sharing between our players. This includes:
Fireside Gathering Event
Examples of data used:
SOCIAL DATA: Tavern Meetup Details
ACTIVITY DATA: Activity region
Chat Applications
Examples of data used:
ACCOUNT DATA: BattleTag
SOCIAL DATA: About me text, chat records, list of groups you are in
Forums
Examples of data used:
ACCOUNT DATA: BattleTag, account name
GAME DATA: Character name
SOCIAL DATA: Forum content
Communications with our players. We communicate with our players about products, services, promotions, studies, surveys, news, updates and events. Blizzard may also use the information to promote and process contests and sweepstakes, fulfill any related awards and serve you relevant ads and content about our products and games.
Specifically, we use your data for the following Publishing purposes:
Surveys
Examples of data used:
COMMUNICATIONS: Age, country, gender, IP address
Mobile Push Notifications
Example of data used:
DEVICE DATA: Phone Device Token
Analytics & Data Segmentation
Examples of data used:
ACCOUNT DATA: Such as: BattleTag, country, state, postcode or city of residence
GAME DATA: Related players
DEVICE DATA: Device ID
ACTIVITY DATA: IP address
Ad Targeting via "Paid Media" and "Custom Audience" (Your unencrypted personal data are never shared with third parties without your consent.)
Examples of data used:
ACCOUNT DATA: Such as: BattleTag, name, country, state, postcode or city of residence, email address, account region
Transactional and Publishing Campaigns and Promotions
Examples of data used:
ACCOUNT DATA: BattleTag, name country, state, postcode or city of residence, email address, account region
Unethical Behavior Prevention. One of our core values is: Play Nice; Play Fair. We devote resources to minimize fraud, cheating and abusive behavior. This includes:
Abuse and Cheat Detention
Examples of data used:
ACCOUNT DATA: Account name, country
ACTIVITY DATA: IP address, region
DEVICE DATA: Device ID
SOCIAL DATA: Related players
GAME DATA: Chat records
Account Compromise Prevention
Examples of data used:
ACCOUNT DATA: Account name, country, BattleTag, date of birth, external account IDs
ACTIVITY DATA: IP address
DEVICE DATA: Device ID
TRANSACTIONS: Payment method
Account Restrictions and Penalties
Examples of data used:
ACCOUNT DATA: Account name, BattleTag
ACTIVITY DATA: Region
CUSTOMER SERVICE: Account restrictions history, penalty history, chat records
Legal proceedings and requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of Blizzard's services or as otherwise allowed or required by applicable law. This includes:
Litigation or Pre-litigation
Examples of data used:
ACCOUNT DATA: Name, home address
CUSTOMER SERVICE: Account notes
LEGAL DATA: Case file
Security Monitoring and Investigations
Examples of data used:
ACCOUNT DATA: Age, name, address, BattleTag, email address, country
ACTIVITY DATA: IP address
DEVICE DATA: Device ID
SOCIAL DATA: Related players
GAME DATA: Chat records
Legal Compliance
Examples of data used:
ACCOUNT DATA: Age, name
What are Blizzard's legal basis for data processing?
We process the above in accordance with the legal bases determined as follows:
- Necessary for the performance of your game contract or any other feature you request or enable. These are required, and ceasing their processing will remove access to certain features or to the game service altogether. This includes using information for:
· Abuse and Cheat Detention and Sanctions
· Account functionality
· Account Compromise Prevention
· Chat Applications
· Contest Participation
· Global Customer Service
· Enrolled esports
· Forums
· Game functionality
· Parental Control
· Battle.net platform functionality
· Enrolled promotions/contests
· Purchases
- Consent. You can withdraw your consent to these at any time.
Consent functionality during account creation
· Receive news and exclusive offers about selected third-party products – Carefully selected news, event information and special offers about third-party product services
Consent functionality in account management – Communications Preferences
· Receive news and special offers from Blizzard Entertainment – Carefully selected news, event information and special offers about Blizzard products and services
· Receive news and special offers about selected third-party products – Carefully selected news, event information and special offers about third-party product services
· Have Blizzard offers recommended to me on partner sites based on data Blizzard collects – Communications personalized to your experience with Blizzard
· Support ticket status updates from Blizzard Customer Support – Receive automatic emails whenever the player's support ticket status changes
· Enable Real ID – The first and last names associated with your account will be visible to Real ID friends. If you do not enable Real ID, only your BattleTag will be visible.
· Suggest me to friends of friends – If enabled, friends of your friends may see you in their suggested friends list.
· Receive private chat messages from friends only – If enabled, you can only receive private chat messages from your friends. This setting may not apply to chat messages sent in-game
- Legitimate interest. We use your data for purposes that are not harmful to your privacy and that can be reasonably expected within the context of your relationship with Blizzard. This includes using information for:
· Ad Targeting via 'Paid Media'
· Ad Targeting via 'Custom Audience' and similar systems—Appropriate ads for players considering their previous purchases (Your unencrypted personal data are never shared with third parties without your consent.)
· Analytics & Data Segmentation
· Business Optimization and Service Development
· Publishing Email - Marketing Campaigns
· Mobile Push Notifications
· Research Groups
· Training & Development
- Legal obligation. We process your data due to a legal obligation or right. This includes using information for:
· Legal Compliance
· Litigation or Pre-litigation
· Security Monitoring and Investigations
With whom may we share your data?
Some of Blizzard's products, services and features require that we share information with other users, our partners and service providers, or for legal reasons or in the event of a dispute.
With partners and service providers. Blizzard may provide information to its vendors, consultants, marketing partners, research firms and other service providers or business partners. For example, we may provide information to such parties to help facilitate event ticket sales, conduct surveys on our behalf and process payments for our products and/or games.
With other players and/or the general public. Information may be viewable by your friends, people in games, or the public in general if you play our games, use certain features in our games, use certain features on our platforms (such as chat applications in game or on the Battle.net platform) or make posts in the forums.
With subsidiaries and affiliates. We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Blizzard processes and stores information at Blizzard Entertainment, Inc. in the United States and may store or process data at Blizzard Entertainment SAS in France.
For legal reasons or in the event of a dispute. Blizzard may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request. This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, user agreements or other policies to protect Blizzard's rights or property or the rights or property of others, or in the event of a claim or dispute relating to your use of our services.
What rights do I have?
Access my data:
You may be able to receive a report about the data Blizzard stores about you. To learn more about accessing your data, please click on this link. https://eu.battle.net/support/help/product/services/1327/1329
Erasure:
You may have a right to request the deletion of some your data. Blizzard is required by law to retain certain data. To learn more about having your data erased or anonymized, please click on this link. https://eu.battle.net/support/help/product/services/1327/1328
Object:
You may object to the processing of your data if you believe Blizzard doesn't have the appropriate rights to engage in that processing. To learn more about making an objection, please click on this link. https://eu.battle.net/support/help/product/services/1327/1330
Rectification:
You can correct your personal data if you feel it's inaccurate. Please log in to your Battle.net account and use the account management settings to make the changes.
Restrict Processing:
You can request that your data no longer be processed in certain cases, for instance, when you exercise your right to object as described above. When objecting, you will be given an option to restrict processing.
Portability:
Data portability is the ability to move data from one company to another (for instance, when you transfer your mobile phone service to another carrier). While this right is not very applicable to Blizzard's current business, we will provide you with an electronic file with your most basic account information, should you request it. To obtain this file, please click here. https://eu.battle.net/support/help/product/services/1327/1342/solution
What are tracking technologies, and how are they used?
Blizzard and our partners, such as marketing partners, may use tracking technologies like cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the websites, tracking users' movements around the websites and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual, as well as an aggregated, basis.
We use cookies for various purposes, including our shopping cart, maintenance of user settings (e.g. language preference) and authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our websites, but your ability to use some of the features or areas of our websites may be limited.
We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear gifs are tied to personal data.
We, and third parties with whom we partner to provide certain features on our websites or to display advertising based on your web browsing activity, use Local Shared Objects such as Flash cookies and Local Storage such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here. http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
What level of security is applied to your personal information?
To help protect the privacy of the data and personally identifiable information you provide to us and that we learn from you, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees indicated above. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.
Note to Parents
We recognize a special obligation to protect personal information about children. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission when they are on-line.
Adolescents aged 13–17 years should ask their parents to read our Privacy Policy and to contact us if they would like any information on our guarantee of confidentiality or to comment on the content. Further, these adolescents should not order or subscribe to any paid service on-line without the permission of a parent or guardian. We ask parents and guardians to be particularly vigilant and to ensure that their minors do not transgress when using our sites or on-line services.
Once a child states that his/her age is under 13, he or she will be unable to register an account with us. We do not knowingly collect or store any personally identifiable information from children under the age of 13. If parents believe that we have unintentionally collected their children's personal information, they may request the deletion of the information by contacting us at EU-Privacy@Blizzard.com.
Blizzard has engineered Parental Controls to help parents monitor and limit, if necessary, the amount of time their children spend interacting with our games. For more information, you may visit our Parental Controls area at https://us.battle.net/support/en/article/32243.
Further Information or Complaints
If you have questions or concerns regarding data protection at Blizzard, you may contact our Data Protection Officer by writing to DPO@Blizzard.com.
Each EU Member State shall provide one or more independent public authority(ies) to be responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the Union ('supervisory authority'). If you feel that Blizzard has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact your nation's supervisory authority.
You also requested a copy of the data Blizzard holds about you. We're very happy to provide this to you, but we can't do so based upon the minimal information you provided. Indeed, you shouldn't want us to provide your data based on such information, which other people may know about you. The data we hold has quite a bit of information that many of our players feel is confidential, such as your account information, chat, the dates and times you have played, your purchase history, etc. The good news is that we've built an automated system to get you your information quickly, and more importantly in a secure manner (rather than sending it to you via email as you requested). One more thing before we send you to our portal: Blizzard has developed a system to try to verify you are who you should be without requiring you to provide us a copy of your identification. You will have a better chance of getting your data without having to provide a copy of your identification if you have one or more of Blizzard's free account-protection systems in place, such as SMS Protect. If you click the following link, you may promptly obtain a copy of your data: https://eu.battle.net/support/en/help/product/services/1327/1329
We wish you a good day.
Sincerely,
The Blizzard Data Protection Team
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