Activision records and processes your voice chats and text messages during gameplay, primarily for safety and moderation but also to improve their features.
This analysis describes what Activision's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Voice and chat data is among the most sensitive categories of personal information; its collection and retention for moderation and product improvement purposes means your in-game conversations may be stored and analyzed by Activision.
Interpretive note: The scope of 'improve our voice and text chat features' as a processing purpose is ambiguous regarding how long voice data is retained and whether it involves human review or automated processing only.
Players' real-time voice and text communications in games like Call of Duty may be recorded, retained, and analyzed by Activision for policy enforcement and product development, creating meaningful privacy exposure for anyone using in-game communication features.
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"Voice and Chat: Activision may collect and process your voice data (e.g., voice chat during gameplay) and text chat. We process voice and text chat for safety and moderation purposes (for instance, to detect cheating, harassment, and other violations of our policies) and to improve our voice and text chat features.— Excerpt from Activision's Activision Privacy Policy
(1) REGULATORY LANDSCAPE: Voice data collection engages GDPR Article 9 considerations where voice data may be used to infer health, political, or other sensitive characteristics, and state-level wiretapping and biometric statutes in the US including Illinois BIPA and California CIPA. The FTC has enforcement authority over unfair or deceptive data practices under Section 5 of the FTC Act. EU data protection authorities may scrutinize whether legitimate interests constitute an adequate lawful basis for voice data retention beyond immediate moderation purposes. (2) GOVERNANCE EXPOSURE: High. The collection of voice data for both safety and product improvement purposes creates dual-purpose processing that requires careful legal basis documentation under GDPR. The retention period for voice data is not specified in the policy, which may be insufficient under GDPR Article 13(2)(a) requirements for retention period disclosure. (3) JURISDICTION FLAGS: Illinois BIPA creates heightened exposure for voice data collection from Illinois residents if voiceprints are derived, as BIPA requires specific written consent. California CIPA may impose notice obligations for recording communications. EU and UK users have stronger rights to object to processing under GDPR Article 21. (4) CONTRACT AND VENDOR IMPLICATIONS: If voice data is processed by third-party moderation vendors, data processing agreements under GDPR Article 28 must specifically cover voice data handling, retention limits, and sub-processor restrictions. Procurement teams should verify whether voice moderation vendors are subject to adequate security certifications. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the retention period for voice recordings, confirm that consent or legitimate interest assessments adequately cover both moderation and product improvement use cases, and assess whether any voice feature uses biometric processing requiring explicit consent under GDPR Article 9 or state biometric laws.
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Voice and chat data is among the most sensitive categories of personal information; its collection and retention for moderation and product improvement purposes means your in-game conversations may be stored and analyzed by Activision.
Players' real-time voice and text communications in games like Call of Duty may be recorded, retained, and analyzed by Activision for policy enforcement and product development, creating meaningful privacy exposure for anyone using in-game communication features.
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