Activision may transfer your personal data to the United States and other countries, using legal mechanisms like Standard Contractual Clauses to attempt to keep that data protected under EU standards.
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
For EU and UK users, the legal adequacy of data transfers to the US is an ongoing regulatory concern following the Schrems II decision, and the effectiveness of Standard Contractual Clauses depends on accompanying transfer impact assessments.
Interpretive note: The policy references SCCs but does not describe whether transfer impact assessments have been conducted or whether EU-US Data Privacy Framework certification applies, creating uncertainty about the robustness of the transfer mechanism in practice.
EU and UK users' personal data, including gameplay activity, voice data, and device identifiers, may be transferred to the US under Standard Contractual Clauses, with the adequacy of protection depending on accompanying legal assessments that are not described in the policy.
How other platforms handle this
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers and partners operate. By using our Services, you acknowledge that your personal information may be transferred to countries outside your country of residence, in...
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"International Transfer of Information: We may transfer your personal information to countries other than the country in which you reside, including to the United States. We will take appropriate measures to ensure that your personal information is protected in accordance with this Privacy Policy and applicable law, such as by using Standard Contractual Clauses approved by the European Commission.— Excerpt from Activision's Activision Privacy Policy
(1) REGULATORY LANDSCAPE: Cross-border transfers from the EEA and UK to the US engage GDPR Chapter V and UK GDPR Chapter V respectively. Standard Contractual Clauses (SCCs) are referenced as the transfer mechanism, which aligns with post-Schrems II practice; however, SCCs must be accompanied by transfer impact assessments (TIAs) where US surveillance laws may undermine their effectiveness. The EU-US Data Privacy Framework provides an alternative adequacy basis for certified US entities, and whether Activision or Microsoft entities are certified is relevant. (2) GOVERNANCE EXPOSURE: Medium. The policy's reference to SCCs is appropriate but the absence of any description of TIAs or supplementary measures may be insufficient under EDPB guidance on international transfers. The expansion of data flows to Microsoft US entities following acquisition increases the volume and complexity of transfers requiring documentation. (3) JURISDICTION FLAGS: EU member states and the UK create the highest transfer compliance exposure. Brazil (LGPD) and South Korea (PIPA) impose their own cross-border transfer requirements that the policy acknowledges but does not detail. (4) CONTRACT AND VENDOR IMPLICATIONS: All data processing agreements with US-based advertising and analytics partners receiving EU/UK personal data should include current SCCs (2021 Commission Decision format) with completed annexes. Transfer impact assessments should be documented and reviewed periodically, particularly in light of the Microsoft acquisition's expanded data flows. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit all transfer mechanisms covering EU/UK to US data flows (including intra-group Microsoft transfers), confirm TIAs have been completed and documented, and assess whether EU-US Data Privacy Framework certification is applicable and sufficient for any particular transfer pathway.
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For EU and UK users, the legal adequacy of data transfers to the US is an ongoing regulatory concern following the Schrems II decision, and the effectiveness of Standard Contractual Clauses depends on accompanying transfer impact assessments.
EU and UK users' personal data, including gameplay activity, voice data, and device identifiers, may be transferred to the US under Standard Contractual Clauses, with the adequacy of protection depending on accompanying legal assessments that are not described in the policy.
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