When you use Epic products that include software from other companies, those companies may collect their own data about you using their own tracking tools, and their privacy policies govern that collection, not Epic's.
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 clause means that your data exposure when using Unreal Engine and other Epic Services may extend beyond what Epic itself collects, to include collection by embedded third-party software vendors whose practices Epic does not control and may not fully disclose.
Developers and end users of Unreal Engine and other Epic Services that include third-party software components should be aware that those third-party components may independently collect data about them under separate privacy policies that Epic is not responsible for.
How other platforms handle this
We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.
We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...
We may share your information with third parties that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with business partners who offer products or services that...
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"When features of the Epic Services are provided by third parties, those third parties may also use automatic data collection technologies and collect information about your use of the Epic Services, their services, or others' websites over time. For example, when you use the Epic Services (e.g., Unreal Engine) that include third-party software, those third parties may collect your information through their technologies. Features provided by third parties are subject to their applicable privacy notices and policies.— Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY LANDSCAPE: Third-party data collection through embedded technologies in Epic Services implicates the ePrivacy Directive and national cookie laws in the EU, GDPR's accountability and data controller identification requirements, and CCPA's disclosure obligations for third parties that collect personal information from California residents on a business's platform. The FTC Act applies to the adequacy of disclosure. Where third-party collection involves cross-context behavioral advertising, CCPA opt-out requirements may apply independently of Epic's own practices. GOVERNANCE EXPOSURE: Medium. Deferring to third parties' privacy notices for data collection that occurs on Epic's own platform and through Epic's own products is a common but potentially insufficient approach under GDPR's accountability principle, which requires controllers to take responsibility for data processing that occurs in connection with their services. Compliance teams should assess whether this deferral is adequate for GDPR purposes or whether Epic assumes joint controller status for some third-party collection. JURISDICTION FLAGS: EU/EEA (GDPR accountability principle, ePrivacy Directive, potential joint controller analysis), United Kingdom (UK GDPR, PECR), California (CCPA/CPRA disclosure obligations for third-party data collection). Developers using Unreal Engine who embed Epic's SDK in their own products may also inherit data collection obligations under applicable law. CONTRACT AND VENDOR IMPLICATIONS: For enterprise and developer users of Unreal Engine, the presence of third-party data collection SDKs within the engine creates compliance obligations for those developers' own products, particularly if they deploy Unreal Engine-based applications to end users. Developers should conduct SDK audits to identify all third-party data collection within Unreal Engine deployments and assess their own disclosure and consent obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should (1) maintain an inventory of all third-party technologies embedded in Epic Services that independently collect user data; (2) assess whether any such collection creates joint controller obligations under GDPR; (3) confirm that user-facing disclosures adequately identify the scope of third-party collection; and (4) advise developer users of Unreal Engine that they may have independent disclosure and consent obligations regarding third-party SDKs in their deployments.
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This clause means that your data exposure when using Unreal Engine and other Epic Services may extend beyond what Epic itself collects, to include collection by embedded third-party software vendors whose practices Epic does not control and may not fully disclose.
Developers and end users of Unreal Engine and other Epic Services that include third-party software components should be aware that those third-party components may independently collect data about them under separate privacy policies that Epic is not responsible for.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Unreal Engine.