User-Generated Content License

What it is

When you submit content such as posts, usernames, or in-game creations to an Activision product, Activision receives a broad license to use, reproduce, modify, and distribute that content, often on a perpetual and royalty-free basis.

Why it matters (compliance & governance perspective)

Users who create or share content through Activision platforms may find that Activision retains ongoing rights to that content even after the user's account is closed or content is deleted, which can interact with data deletion rights under GDPR or CCPA.

Consumer impact (what this means for users)

The perpetual, royalty-free license Activision asserts over submitted user content means the company may continue to use your submitted content for commercial or operational purposes without compensation, and possibly beyond the life of your account relationship.

What you can do

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 17 (right to erasure) and Article 7 (consent withdrawal) for EU/EEA users, where a perpetual content license asserted over personal data may conflict with data subjects' erasure rights. CCPA grants California consumers the right to request deletion of personal information, which may include user-submitted content. The FTC Act governs whether the scope of the license is adequately disclosed to consumers at the point of consent. 2) GOVERNANCE EXPOSURE: Medium. Perpetual content licenses in consumer-facing gaming and social platforms are common industry practice, but the intersection with GDPR erasure rights creates a documented area of regulatory tension. Where user-submitted content constitutes personal data (e.g., a username, avatar, or message containing identifying information), the license assertion may not override statutory deletion rights. 3) JURISDICTION FLAGS: EU/EEA users have the strongest statutory grounds to challenge perpetual content licenses where the content constitutes personal data, given GDPR's erasure rights. California users may assert CCPA deletion rights. The practical enforceability of the perpetual license against deletion requests will depend on how Activision's data infrastructure distinguishes between content-as-data and content-as-licensed-material. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party developers or content partners whose work may be submitted through user interfaces should confirm whether this license could inadvertently capture their intellectual property. Vendor agreements involving user-generated content pipelines should clarify the chain of license rights and any liability for downstream use. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should map user-generated content types against personal data categories under GDPR and CCPA to identify where the perpetual license assertion intersects with statutory deletion obligations. Consent mechanisms at the point of content submission should clearly disclose the scope of the license. Data retention policies should address whether 'deleted' user content remains subject to the license or is genuinely purged.

Applicable agencies

Provision details

Other risks in this policy

• Mandatory Binding Arbitration and Class Action Waiver high
• Age Requirement and Parental Consent for Minors medium
• Account Suspension and Termination medium
• English Language Prevails Over Translations medium
• Acceptance by Use medium

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