The policy authorizes disclosure of children's account information to gaming console operators, app publishers on the Epic Games Store, professional advisors, and law enforcement for operational and protective purposes, and to additional third parties with parent/guardian permission for account linking and third-party sign-in.
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
This provision establishes the categories of third parties that receive children's personal information under COPPA's disclosure framework. The inclusion of app publishers on the Epic Games Store as recipients of child account information for operational purposes is operationally significant, as it means publishers whose games children download may receive child account data without requiring separate parental consent where Epic characterizes the disclosure as integral to service operation.
Interpretive note: Whether specific disclosures to app publishers and gaming console operators satisfy COPPA's operational necessity exception depends on the nature of each disclosure and is a regulatory determination, not solely an assertion within the policy.
Under this provision, children's account information is disclosed to gaming console operators and app publishers on the Epic Games Store as part of routine service operations, and to additional third parties only with parental permission. The agreement identifies these categories of recipients but does not enumerate all specific third-party recipients by name.
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"We disclose a child's account information to third parties: (1) for purposes integral to the operation and protection of our Epic Services (e.g., to gaming consoles, publishers of games or apps acquired through Epic Games Store, professional advisors, and law enforcement), or (2) with a parent/guardian's permission (e.g., for account linking and signing into third-party services).Excerpt from Unreal Engine's Epic Games Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages COPPA's restrictions on disclosure of children's personal information (16 CFR 312.5) and GDPR's data sharing and controller/processor relationship requirements.
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This provision establishes the categories of third parties that receive children's personal information under COPPA's disclosure framework. The inclusion of app publishers on the Epic Games Store as recipients of child account information for operational purposes is operationally significant, as it means publishers whose games children download may receive child account data without requiring separate parental consent where Epic characterizes …
Under this provision, children's account information is disclosed to gaming console operators and app publishers on the Epic Games Store as part of routine service operations, and to additional third parties only with parental permission. The agreement identifies these categories of recipients but does not enumerate all specific third-party recipients by name.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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