INSIGHT

What does COPPA and GDPR-K compliance mean for children’s games?

7 minUTE read

How can you collect data, use analytics, and run ads in games targeting kids and stay on the right side of regulations, compliance, and ethics?

This article is for anyone designing, developing, or producing a game for young audiences. Whether it’s a game app for the App Store or Google Play Store, or using a platform like Roblox or Minecraft, there’s something in here for you.

Why You Need to Understand COPPA and GDPR-K Compliance in Kids’ Games

In the world of children’s digital entertainment, compliance with child privacy laws like COPPA and GDPR-K isn’t just a regulatory obligation—it’s essential for the trust and safety of young players. Whether you're a children’s brand looking to expand into games, or a publisher or developer, understanding COPPA and GDPR-K will help ensure that your game aligns with best practices and regulatory requirements. Creating a super-safe experience for young players is all of our responsibilities.

Essentially, getting COPPA and GDPR-K compliance right for kids' games can involve a complex mix of notifying players about data collection, and in some cases getting parental consent. All of that means you need expert guidance. It needs to be done in a way that is both compliant and also doesn’t detract from the appeal of the game.

Here’s an essential breakdown of what these laws entail and how they impact games, whether in app form or on platforms like Roblox and Minecraft.

What are COPPA and GDPR-K?

COPPA (Children’s Online Privacy Protection Act) is a U.S.-based regulation designed to protect the online data of children under 13. It applies to all digital platforms, not just games, that collect personal information from young users, even if the company itself isn’t based in the United States.

This regulation means that we have to obtain verifiable parental consent before collecting any data that could identify a child, such as names, locations, or IP addresses. Learn more about COPPA here.

GDPR-K refers to a specific clause within the General Data Protection Regulation (GDPR) in the EU, which safeguards data protection for children under 16 (or 13, depending on the country). Like COPPA, GDPR-K requires parental consent for processing personal data, but it also has more extensive data rights for children, such as the right to access, correct, or delete data. More about GDPR-K can be found here.

If you followed those links, you will have quickly realised how complex it can potentially be to comply with COPPA and GDPR for children’s games. This is where the benefit of working with a games studio experienced with COPPA and GDPR-K compliance for kids' games can save you time and money.

How COPPA and GDPR-K Impact Game Design

One thing to note immediately is that COPPA and GDPR-K are not the same. If you comply with one, you are not necessarily complying with the other.

To create a COPPA and GDPR-K-compliant game, we have to ensure data privacy in all aspects of design. For example:

Data collection: in reality, compliance means limiting data collection as much as possible. When we design children’s games that comply with COPPA and GDPR-K, we avoid collecting any data not crucial for gameplay. As often as possible, we choose to anonymise or even eliminate data collection entirely, to sidestep regulatory issues.

Parental Consent: sometimes we can’t avoid it, and games need to perform some data collection. To meet COPPA and GDPR-K requirements, our games need systems to confirm parental consent. This might be through parental portals or verification processes before allowing any personal data collection. This is a really complex area, and we work with tried and tested systems that mean we’re operating within the latest regulations and making the process as simple and safe as possible for both our players and our clients. That way we’re taking no chances.

In-Game Communication: Games should also control how players interact. As free chat or messaging could expose children to privacy risks, we recommend thinking very hard before going down that design route. To reduce risks, our games use predefined responses or rely on heavily moderated chat systems within their platforms.Overall, our job as kids' game developers is to structure gameplay and design interfaces that balance fun and engagement with robust privacy protections and the needs of our clients. That way, everyone stays safe, and everyone wins.

Overall, our job as kids' game developers is to structure gameplay and design interfaces that balance fun and engagement with robust privacy protections and the needs of our clients. That way, everyone stays safe, and everyone wins.

Compliance on Platforms like Roblox and Minecraft

When we make kid’s games using platforms like Roblox and Minecraft, much of the COPPA and GDPR-K compliance comes built-in. However, we can’t hand over the responsibility for compliance entirely to the platforms. Each game built for those platforms also has to adhere to COPPA and GDPR-K rules, especially where it explicitly targets children. Here are some things to think about:

Roblox: Roblox already implements parental control options and has moderation. However, game creators still have to be mindful of in-game purchases and ensure no data is collected without consent. Compliance means limiting features like in-game messaging to prevent personal data sharing. Roblox provides the ability for creators to do this.

Minecraft: if a game or mod in Minecraft targets young audiences, we still have to ensure that any add-ons or multiplayer features are COPPA and GDPR-K compliant. This could mean limiting data collection through servers and other aspects of implementation.

There is a danger that developers working on platforms like Roblox and Minecraft assume that games built on Roblox or Minecraft are inherently COPPA and GDPR-K compliant, but that isn’t always the case.

If you’re choosing a games studio for a Roblox or Minecraft game that targets children, you should ask about their experience with COPPA and GDPR-K compliance.

Rules Around Advertising to Kids in Game Apps

We generally advise staying away from in-game adverts for kids' games. Subscriptions, one-time purchases, and in-app purchases are the more common ways of monetising children’s games and apps. However, there are instances where in-game ads can be appropriate, so let’s run through the challenges associated with advertising in children’s games.

Advertising within children’s apps is heavily restricted under COPPA and GDPR-K to prevent manipulative marketing practices and inappropriate content exposure. All the major app stores, including Apple’s App Store and the Google Play Store, build COPPA and GDPR-K compliance into their acceptance criteria.

Ad Targeting Restrictions: Behavioural advertising (based on personal data) is prohibited under COPPA and GDPR-K. Any ads targeting children’s apps must not collect data from the users. Instead, generalised ads, often called “contextual ads,” are permitted because they don’t rely on data profiling.

Content of Ads: Advertisements must be appropriate for children. For instance, ads should avoid promoting products that are not suitable for young audiences. Getting this wrong can damage a brand’s reputation and, in extreme cases, lead to legal action.

Clear Distinction of Ads: Compliance also requires making ads distinguishable from game content. Younger users should understand what’s an ad and what’s part of the game. We recommend approaching this by labelling ads explicitly or using very clear visual indicators to separate them from gameplay.

There are kid-safe ad networks that provide assurance that the ads are COPPA and GDPR-K compliant.

Why Compliance Matters

Getting COPPA and GDPR-K compliance right for kids' games and apps is important. For children’s IP holders, failing to comply can lead to costly fines and reputational damage. There have been some very high-profile fines issued to some of the world’s biggest entertainment brands. If you want to find out more, then a quick Google search will reveal some astonishing figures.

Beyond regulatory reasons, COPPA and GDPR-K compliance is critical to building trust. When your game complies, it sends a clear message to families that their children’s privacy is taken seriously, which can be a significant motivator for capturing the loyalty of brand-conscious parents.