Sharing with Advertising and Analytics Partners

What it is

Activision shares your personal information with outside advertising companies and data analytics firms to show you targeted ads.

Why it matters (compliance & governance perspective)

Sharing personal data with advertising networks for behavioral targeting is the mechanism through which your gameplay activity, device identifiers, and inferred interests may follow you across the internet beyond Activision's own platforms.

Consumer impact (what this means for users)

Personal information including device identifiers, gameplay behavior, and inferred interests may be shared with third-party advertising networks, potentially enabling cross-site and cross-app tracking and targeted advertising based on your Activision activity.

What you can do

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Under CCPA/CPRA, sharing personal information with third-party advertising networks for cross-context behavioral advertising constitutes 'sharing' subject to the right to opt out under California Civil Code Section 1798.120. Under GDPR, behavioral advertising requires either valid consent under Article 6(1)(a) or a legitimate interests basis with a documented balancing test; the policy cites legitimate interests for some advertising uses, which may face challenge under GDPR recital 47. The FTC has enforcement authority and has issued guidance on data broker and advertising network practices. (2) GOVERNANCE EXPOSURE: High. The breadth of the advertising partner network is not enumerated in the policy, making it difficult for users to assess the full scope of data sharing. The absence of a specific list of advertising partners or categories of partners shared with may be insufficient under GDPR Article 13 transparency requirements. (3) JURISDICTION FLAGS: California residents have a statutory right to opt out of sharing for behavioral advertising. EU and UK users must receive a valid consent mechanism for behavioral advertising cookies and data sharing. Brazil (LGPD) and South Korea (PIPA) impose similar consent requirements for marketing data transfers. (4) CONTRACT AND VENDOR IMPLICATIONS: Data sharing agreements with advertising partners should include CCPA service provider or contractor terms where applicable to avoid triggering opt-out obligations for operational advertising uses. GDPR Article 26 joint controller arrangements may apply where advertising partners co-determine processing purposes. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the full list of advertising and analytics partners receiving personal data, confirm that CCPA opt-out signals (including Global Privacy Control) are honored, and verify that EU consent management platform configurations align with current IAB TCF requirements or equivalent valid consent mechanisms.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Collection of Voice and Chat Data high
• Microsoft Affiliate Data Sharing medium
• Children's Privacy and Parental Consent high
• California Opt-Out Rights (CCPA/CPRA) medium
• Cross-Border Data Transfers medium
• Gameplay and Behavioral Data Collection medium

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