If voice reporting is enabled, short recordings of your voice chat are saved on participants' devices, and if someone reports a violation, those recordings may be sent to Epic for review.
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
Voice recordings are sensitive personal data, and storing them on other participants' devices without the user's direct control raises questions about who has access to those recordings and how long they persist before a report is made.
Interpretive note: Whether voice snippets constitute biometric data or voice prints triggering state biometric privacy law obligations depends on how the data is technically processed, which is not specified in the policy.
Your voice communications in Epic games may be stored on the devices of other players in the channel, not just your own, and can be transmitted to Epic if another participant files a report, meaning you have limited control over this data once it exists on others' devices.
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"When you use our voice chat feature and voice reporting is enabled in a voice channel, snippets of voice chat are stored on your device and the devices of participants in the voice channel. If a violation of our terms or policies (e.g., Community Rules) is reported, these snippets may be transmitted to Epic to review that reported violation and enforce our terms and policies.— Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY LANDSCAPE: Voice recordings may constitute biometric data or voice prints under certain state laws, including Illinois BIPA, Texas CUBI, and Washington's My Health MY Data Act, depending on how they are processed. At the federal level, the Electronic Communications Privacy Act (ECPA) and state wiretapping statutes may be implicated by multi-device storage of voice communications. GDPR Article 9 may apply if voice data is processed in ways that could reveal health, political, or other special category information. The FTC's general unfair or deceptive practices authority is also relevant if the disclosure of this practice is found to be inadequate. GOVERNANCE EXPOSURE: Medium. The storage of voice snippets on other participants' devices is an operationally distinct design choice that creates data governance complexity, as Epic does not directly control the retention period or access controls on those third-party devices prior to a report being filed. The policy references FAQs for retention details rather than specifying retention periods in the policy itself, which may be insufficient for GDPR transparency requirements. JURISDICTION FLAGS: Illinois (BIPA, if voice prints are extracted), Texas (CUBI), Washington state (My Health MY Data Act), EU/EEA (GDPR transparency and data minimization requirements), United Kingdom (UK GDPR). In jurisdictions with two-party or all-party consent requirements for recorded communications, the adequacy of disclosure through game settings rather than explicit consent at the point of recording may require review. CONTRACT AND VENDOR IMPLICATIONS: If Epic transmits voice snippets to third-party moderation or content review vendors, data processing agreements must cover the specific handling and deletion of audio recordings. Procurement teams should confirm that any AI-assisted moderation tools applied to voice snippets comply with applicable biometric data laws. COMPLIANCE CONSIDERATIONS: Compliance teams should (1) confirm that the in-game disclosure of voice snippet storage satisfies transparency requirements under applicable law; (2) assess whether voice snippet processing constitutes biometric data collection under state laws and, if so, implement required consent mechanisms; (3) specify retention periods for voice snippets in the policy or linked FAQs to meet GDPR Article 13 requirements; and (4) review whether the multi-device storage design satisfies data minimization principles.
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Voice recordings are sensitive personal data, and storing them on other participants' devices without the user's direct control raises questions about who has access to those recordings and how long they persist before a report is made.
Your voice communications in Epic games may be stored on the devices of other players in the channel, not just your own, and can be transmitted to Epic if another participant files a report, meaning you have limited control over this data once it exists on others' devices.
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