Zynga 2015 Annual Report Download - page 37

Table of Contents
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
one jurisdiction to another and may conflict with other rules or our practices. It is also possible that new laws, policies, legal obligations or industry codes of
conduct may be passed, or existing laws, policies, legal obligations or industry codes of conduct may be interpreted in such a way that could prevent us from being
able to offer services to citizens of a certain jurisdiction or may make it more costly or difficult for us to do so. For example, if a country enacted legislation that
required data of their citizens gathered by online services to be held within the country, we may not be able to comply with such legislation or compliance could be
so difficult or costly that we chose not to stop offering services to citizens of that country. Any failure or perceived failure by us to comply with our privacy
policies, our privacy-related obligations to players or other third parties, or our privacy-related legal obligations, or any compromise of security that results in the
unauthorized release or transfer of personally identifiable information or other player data, may result in governmental enforcement actions, litigation or public
statements against us by consumer advocacy groups or others and could cause our players to lose trust in us, which could have an adverse effect on our business.
Additionally, if third parties we work with, such as players, vendors or developers, violate applicable laws or our policies, such violations may also put our players’
information at risk and could in turn have an adverse effect on our business.
In this area many states have passed laws requiring notification to players when there is a security breach for personal data, such as the 2002 amendment to
California’s Information Practices Act, or requiring the adoption of minimum information security standards that are often vaguely defined and difficult to
practically implement. In January 2014, the Federal Trade Commission announced a settlement with Apple related to in-app purchases made by minors. The costs
of compliance with these laws may increase in the future as a result of changes in interpretation. Moreover, in the areas of privacy, information security, data
protection, consumer protection and protection of minors, foreign laws and regulations are often more restrictive than those in the United States. In particular, the
European Union and its member states traditionally have taken broader views as to types of data that are subject to data protection, and have imposed legal
obligations on companies in this regard. Any failure on our part to comply with laws in these areas may subject us to significant liabilities.
OurbusinessissubjecttoavarietyofotherU.S.andforeignlaws,manyofwhichareunsettledandstilldevelopingandwhichcouldsubjectustoclaimsor
otherwiseharmourbusiness.*
We are subject to a variety of laws in the United States and abroad, including state and Federal laws regarding consumer protection, electronic marketing,
protection of minors, data protection, competition, taxation, intellectual property, export and national security, that are continuously evolving and developing. The
scope and interpretation of the laws that are or may be applicable to us are often uncertain and may be conflicting,
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