When you use Epic's AI tools, the information you type in and the AI's responses back to you may both contain identifying information that Epic processes.
This analysis describes what Unreal Engine'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
Users of AI-powered features should be aware that their inputs and the resulting AI outputs may be treated as personal data and processed by Epic, though the policy does not specify whether these inputs are used to train or improve AI models.
Interpretive note: The policy does not specify whether user inputs to AI features are retained for model training or shared with third-party AI providers, creating interpretive uncertainty about the full scope of processing.
Any identifying information you provide through Epic's AI features like Developer Assistant is processed by Epic, and the policy does not specify whether your inputs are retained, used for model training, or shared with third-party AI providers, creating some uncertainty about the data lifecycle.
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"When you use AI-powered features (e.g., Epic Developer Assistant), we use your inputs (e.g., information you submit that may identify you) to generate outputs (e.g., responses that may identify you).— Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY LANDSCAPE: AI-generated processing of user inputs containing personal data implicates GDPR Article 22 if outputs constitute automated decision-making with significant effects, and requires a documented lawful basis under GDPR Articles 6 and 9 if special category data is involved. The EU AI Act, which entered into force in 2024, establishes transparency and documentation obligations for certain AI systems that may apply depending on Epic's AI feature classification. The FTC has issued guidance on AI transparency and unfair data practices. The policy does not clarify whether user inputs are used for AI model training, which is a material disclosure gap relative to emerging regulatory expectations. GOVERNANCE EXPOSURE: Medium. The disclosure is brief and does not specify data retention periods for AI inputs and outputs, whether user data is used to train or fine-tune AI models, or whether AI processing involves third-party AI providers. These gaps may not satisfy transparency requirements under GDPR Articles 13 and 14 or emerging AI-specific disclosure obligations. JURISDICTION FLAGS: EU/EEA (GDPR transparency requirements, EU AI Act obligations), United Kingdom (UK GDPR, proposed AI regulation), California (CCPA/CPRA sensitive personal information if inputs reveal sensitive categories), United States generally (FTC AI guidance and potential rulemaking). Developer-facing AI tools like Epic Developer Assistant may also implicate professional or proprietary information submitted by business users. CONTRACT AND VENDOR IMPLICATIONS: If Epic uses third-party AI model providers to power features like Developer Assistant, data processing agreements with those providers must address the handling of user input data, prohibition on secondary training use, and deletion obligations. B2B users and developers who submit proprietary information through AI tools should assess whether Epic's contractual terms adequately protect their confidential data. COMPLIANCE CONSIDERATIONS: Compliance teams should (1) clarify in the policy or supplementary documentation whether user inputs to AI features are used for AI model training or improvement; (2) specify retention periods for AI input and output data; (3) identify any third-party AI providers processing user data and confirm appropriate contractual protections; and (4) assess EU AI Act compliance obligations for each AI-powered feature offered to EEA users.
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Users of AI-powered features should be aware that their inputs and the resulting AI outputs may be treated as personal data and processed by Epic, though the policy does not specify whether these inputs are used to train or improve AI models.
Any identifying information you provide through Epic's AI features like Developer Assistant is processed by Epic, and the policy does not specify whether your inputs are retained, used for model training, or shared with third-party AI providers, creating some uncertainty about the data lifecycle.
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