Zynga 2014 Annual Report Download - page 37

Table of Contents
Evolving regulations, industry standards and practices by platform providers concerning data privacy could prevent us from providing our
games to our players, or require us to modify our games, thereby harming our business.
The regulatory framework for privacy issues worldwide is currently in flux and is likely to remain so for the foreseeable future. Practices
regarding the collection, use, storage, transmission and security of personal information by companies operating over the Internet and mobile
platforms are under increased public scrutiny, and civil claims alleging liability for the breach of data privacy have been asserted against us. The
U.S. government, including the Federal Trade Commission, the Department of Commerce, U.S. Congress, and various State Attorneys General
are continuing to review the need for greater regulation for the collection of information concerning consumer behavior on the Internet, including
regulation aimed at restricting certain targeted advertising practices. There is also increased attention being given to the collection of data from
minors. For instance, the Children’s Online Privacy Protection Act requires companies to obtain parental consent before collecting personal
information from children under the age of 13. In addition, the European Union has proposed reforms to its existing data protection legal
framework, which may result in a greater compliance burden for companies with users in Europe. Various government and consumer agencies
have also called for new regulation and changes in industry practices. For example, in February 2012, the California Attorney General
announced a deal with Amazon, Apple, Google, Hewlett-Packard, Microsoft and Research in Motion to strengthen privacy protection for users
that download third-party apps to smartphones and tablet devices. Additionally, in January 2014, the Federal Trade Commission announced a
settlement with Apple related to in in-app purchases made by minors.
We began operations in 2007. While our administrative and technical systems have developed rapidly, during our earlier history our
practices relating to intellectual property, data privacy and security, and legal compliance may not have been as robust as they are now, and there
may be unasserted claims arising from this period that we are not able to anticipate. In addition, our business, including our ability to operate and
expand internationally, could be adversely affected if laws or regulations are adopted, interpreted, or implemented in a manner that is
inconsistent with our current business practices and that require changes to these practices, the design of our website, games, features or our
privacy policies. In particular, the success of our business has been, and we expect will continue to be, driven by our ability to responsibly use
the data that our players share with us. Therefore, our business could be harmed by any significant change to applicable laws, regulations or
industry practices or the requirements of platform providers regarding the use or disclosure of data our players choose to share with us, age
verification, underage players or the manner in which the express or implied consent of consumers for such use and disclosure is obtained. Such
changes may require us to modify our game features and advertising practices, possibly in a material manner, and may limit our ability to use the
data that our players share with us.
We process, store and use personal information and other data, which subjects us to governmental regulation and other legal obligations
related to privacy, information security, data protection, consumer protection and protection of minors and our actual or perceived failure to
comply with such obligations could harm our business.
We receive, store and process personal information and other player data, and we enable our players to share their personal information
with each other and with third parties, including on the Internet and mobile platforms. There are numerous federal, state and local laws around
the world regarding privacy and the storing, sharing, use, processing, disclosure and protection of personal information and other player data on
the Internet and mobile platforms, the scope of which are changing, subject to differing interpretations, and may be inconsistent between
countries or conflict with other rules. We generally comply with industry standards and are subject to the terms of our own privacy policies and
privacy-related obligations to third parties (including voluntary third-party certification bodies such as TRUSTe). We strive to comply with all
applicable laws, policies, legal obligations and certain industry codes of conduct relating to privacy and data protection, to the extent reasonably
attainable. However, it is possible that these obligations may be interpreted and applied in a manner that is inconsistent from
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