Creator Ops · Season 1

Privacy policy

Draft 0.3 · 5 November 2026 · prepared for legal review

This is a draft. It describes what the Creator Programme's systems do today, written from the engineering data register to sit beside the Programme's Terms and Conditions. Items in [square brackets] are still to be confirmed by legal before this becomes the published policy.

1. Who we are

The Call of Duty: Modern Warfare 4 Season 1 Creator Programme ("the Programme") is run by NewGen Advertising Limited, a company registered in England and Wales under number 11553454, of 5th Floor, New Penderel House, 283 to 288 High Holborn, London WC1V 7HP ("NewGen", "we"). NewGen is an independent controller of the personal data described here: we decide what our systems collect for the Programme and why, and we are responsible for it. When we share your results with Activision Publishing, Inc. ("Activision") (section 4), Activision handles them as a separate, independent controller under its own privacy policy at https://www.activision.com/legal/privacy-policy. This policy describes what NewGen's systems collect and what they do with it. You can reach us about privacy by writing to NewGen Advertising Limited, marked "Privacy", at 5th Floor, New Penderel House, 283 to 288 High Holborn, London WC1V 7HP ("our office").

2. What this policy covers

The Creator Portal, where you apply and manage your account; the verification of gameplay from your public live streams on Twitch and Kick; and the stream overlay. It applies to creators who apply to or take part in the Programme, and to the other players whose names appear on their screens (section 3.3). Community Giveaways for viewers are not run through these systems and are not covered here.

3. What we collect, why, and on what basis

3.1 Your account and application

Your email address and a password (you register with a link or code we email you and then set a password; Supabase Auth stores it as a hash, we never see it, and we record only that one is set), your creator name, country, primary platform, content focus, the language you play the game in, the public handles of the channels and accounts you declare, your Activision ID (your in-game name and its number), the clan tag you wear in game, and the version and time of the terms you accepted. If you play on a second account, the team may record its Activision ID too, from your contract or your own scoreboard. We also keep the campaigns you are enrolled in and when, the challenges you star, and when and in which match the system first read your clan tag beside your own name. We use these to run the Programme, to know where to look for your streams, to confirm it is you on the scoreboard, and to contact you. Basis: performing the Terms with you, and the steps you ask us to take before them.

3.2 Gameplay from your public live streams

When a channel you declared on Twitch or Kick is live in the Call of Duty category, our service (FrameOps) reads the public stream the way a viewer sees it, one frame a second, and works out what happened in each match from what the screen shows: the mode, map, result and score, your kills, deaths and other figures, the kill feed, on-screen notifications and medals, the end-of-match scoreboard, and in Warzone and DMZ their counters, squad lists, the places you land and the end screens. Frames are read in memory and discarded. We never store the video. For each match we store its statistics; whose game the read judged it to be; still images of its scoreboards and key moments (end screens, death screens, the map card, the result screen) and small thumbnails (each step of your kills, each medal, the weapon at each kill), each with the time in the stream it was shown; the log of what was read and when; and the automated review. An image shows whatever your stream showed at that moment, including your webcam and your chat where you place them over the game. We also note the picture quality your channel offers, to check the 1080p minimum. We use all of this to verify challenges and settle rewards. Basis: performing the Terms with you.

3.3 Other players on your screen

A scoreboard lists everyone in the match, usually twelve players, and only one of them is you; the kill feed, death screens and squad lists name other players too. We store the other players' in-game names and statistics as they appear there, because the team totals are how we check that your own figures were read correctly, and because some challenges count the teammates whose names carry a programme creator's clan tag (the evidence for those challenges keeps the count, never the names). Where the system finds that a match is another player's footage, that player's name appears in the reason it records. Stream chat shown in an image carries viewers' names. We do not contact any of these people, do not build profiles of them, and do not use their data for anything else. Basis: our legitimate interest, and the creators', in verifying results accurately before rewards are paid. We have weighed it against these players' interests: their names were already shown publicly on the creator's stream, we keep only what the screen showed, we use it for nothing else, we delete it on the date in section 6, and anyone can ask for it to be removed. A player who wants their name or an image removed can ask us (section 8).

3.4 Whether you are live, and your profile picture

Every 30 seconds we ask Twitch and Kick whether each declared channel is live, with its title, category, start time and viewer count, so a read can start when you go live. Each answer replaces the last, so no history of your viewer numbers is kept. Once a day we fetch the public address of your channels' profile pictures to show your picture in the portal and to our team. All of this is public information about a public channel.

3.5 Connected accounts

If you choose to connect a platform account (today, Twitch), we hold an access token for it, encrypted, with no permissions beyond confirming the account is yours. It is deleted the moment you disconnect, and it is never shown to anyone, including you.

3.6 Verification records

Every decision on a match or a challenge is kept: whether it was approved, corrected or rejected, the reason, who made it (the system or a named member of the NewGen team) and when, as the record of how a reward was settled. A correction is kept as a separate record beside the original read, which is never overwritten. Section 7 says which decisions the system makes on its own.

3.7 Disputes, clips and links you send

If you dispute a challenge, we keep the stream and the time you named, your note and the team's reply. If you submit a clip, we keep the link or the stream time you gave, your note, what FrameOps read from the clip and the decision; nothing read from a clip is saved as a match. If you send us a link to a recording from your Matches page, we keep the link, when you sent it and what the team decided; a recording the team queues is read exactly as described in section 3.2.

3.8 Your XP and the standings

Your XP is the sum of the points of the challenges verified for you. The points for each challenge, with any multiplier that applied (a weekly streak, Community Squad membership, a double-XP window), are recorded when it is verified, and whether you are in the Community Squad is kept on your account. When the standings are open, other creators in the Programme see your display name, your country and your XP beside theirs, and nothing else about you; you see your own place, the size of the field and the XP at the 50th place, for the week and for the season. The standings are off until the Programme opens them. When a week closes, its final ranking (every active creator's place and XP) is kept as the record of who won that week's prizes, and the winners are emailed. Prizes are handed over by the team outside the portal; nothing is claimed or spent in it.

Anyone can see the public leaderboard at /leaderboard: once the standings are open, it lists every Season 1 creator who has XP, by display name, country and XP, and nothing else about you.

3.9 The stream overlay

If you create a stream overlay link on your account page, we keep only a scrambled (hashed) form of its key, never the key itself. Anyone with the link sees what the overlay shows: your XP and standing, your open challenges, whether your stream is being read, and your last five games (for an approved game, its kills, deaths, placing and map). Keep the link private; you can replace it or switch it off on your account page at any time.

3.10 Emails we send you

We email you the decision on your application, and, while you are in the Programme, enrolments, challenge outcomes, prize notices and the occasional note from the team. Those programme emails stop the moment you ask, from your account page or the link in any of them; the decision on your application and your sign-in links and codes are your account and always come. We keep a record of each message sent (who, what kind, when, and the note a team member wrote for you), not its body.

3.11 Cookies and logs

The portal sets a cookie that keeps you signed in. While you connect your Twitch account it sets a second one for ten minutes, and if you open the Creator Hub's demo, a third keeps the demo on for a day. We use no advertising or analytics cookies. Our servers keep ordinary technical logs of the requests they receive. Passwords and connected-account tokens are never written to them, and the code in a one-time sign-in link is masked before a request is logged.

4. Who we share data with

Activision, in the United Kingdom, receives your results, your challenge progress and the evidence for them, for reporting, audit and reward fulfilment (clause 6.2 of the Terms). It uses them as a separate, independent controller (section 1).
Supabase hosts our database, our sign-in system and the stored images, in Frankfurt, Germany, as our processor.
Railway runs our services, as our processor, in its EU West region in the Netherlands. Frames are processed in memory there and not kept.
RunPod hosts the review model we run ourselves, as our processor, in its European data centres (in the European Union, and in Iceland and Norway in the European Economic Area). Twice per match it receives the scoreboard image (for a Warzone game without a squad board, its match summary or end screen) and the match's statistics, including the other players' names, to re-read the scoreboard and review the result.
Resend delivers our emails, as our processor, from its EU region: your sign-in links and codes and the programme emails in section 3.10. It receives your email address and each message, and keeps delivery records.
Twitch and Kick receive our requests for your live status, your profile picture and your public stream, as any viewer's browser would.

We do not sell personal data and we do not share it for advertising.

5. Where data is processed

Everything our systems collect is processed in Europe: our database, sign-in system and stored images in Germany (Frankfurt), our services in the Netherlands, the review model in RunPod's data centres in the European Union, Iceland and Norway, and our emails in Resend's EU region. When we share your results, challenge progress and evidence with Activision (section 4), we share them with Activision in the United Kingdom.

6. How long we keep it

The Programme Period runs from 9 November 2026 to 4 January 2027. We keep the records described here for 12 months after it ends, and delete them automatically on 4 January 2028. The records of rewards settled are kept for the same period. If a dispute is still open at that date, or the law requires us to keep something longer, we keep only what that needs, and only for as long as it needs it. You can delete your account at any time from your account page. Deletion removes your profile, your declared accounts and any connected-account token, your overlay link, your match records and images, your challenge progress and your sign-in. We keep one record that a deletion was requested and carried out: the former identifiers, who asked, the reason and the outcome, and nothing else about you.

7. Automated decisions

Most decisions on your matches and challenges are made by the system, without a person:

It approves a match when FrameOps's read and the automated review of the scoreboard image agree, nothing is flagged, the stream was at 1080p or higher and the game is your own.
It rejects a match when it finds that the footage is another player's, that nothing on screen names any player, that the end of the match was not shown, that the match repeats one already recorded, or that there is no Call of Duty game on it.
It signs off a challenge once approved matches meet its conditions, and accepts a submitted clip when the clip is your own footage and shows what the challenge asks.
If you have not given an Activision ID, it sets one when the scoreboards of three of your games show the same name in the row the game marks as yours, and no other name, and then checks your waiting games against it.

Everything the system cannot decide goes to a member of the NewGen team, who also checks one automatic approval in every hundred. A person's decision always stands over the system's. You can ask for any automatic decision to be looked at by a person, through a dispute on the Creator Portal or by writing to our office (section 1).

8. Your rights

You have the right to access the personal data held about you, to have it corrected, to have it erased, to restrict or object to its processing, to receive it in a portable form, and to have a person review a decision made about you by automated means, within the limits the law sets. You can correct your declared accounts, request a change to your Activision ID and delete your account on your account page. For anything else, write to our office (section 1); as the controller, NewGen answers your request, including for what we have shared with Activision. For what Activision does with your results once it has them, you can also contact Activision through its privacy policy. You can also complain to the Information Commissioner's Office in the UK (ico.org.uk), or to the data protection authority in the country where you live.

If you are a player who appeared on a creator's scoreboard or screen and want your name or an image removed, contact us with your in-game name and, if you know them, the date and the creator. We will remove it unless we have a reason we must keep it, which we will explain.

9. Age

The Programme is for creators aged 18 or over, or the age of majority in their country of residence if that is higher.

10. Changes

We will post any change here with a new version and date, and tell enrolled creators of material changes before they take effect.