Engagement is the product.For children, it is the risk.
The same data that tunes the game can breach the Act.
In one line: Where it is linked to an account, device identifier or other data that identifies a player, it is personal data and subject to DPDPA.
Every event you log is a sentence in a file about a person.
The scene
Telemetry recorded every tap, pause and purchase, keyed to device ID. The monetisation team built ‘whale prediction’ from it. Three of the top ten predicted whales were fourteen.
Where the thinking breaks
Two streams
Split telemetry into gameplay tuning, which can be aggregated early, and commercial targeting, which must exclude children and respect consent.
Monday morning
- 01List every telemetry event.
- 02Mark which feed monetisation.
- 03Exclude likely minors from those models.
Questions, answered plainly
Is game telemetry personal data under DPDPA?
Where it is linked to an account, device identifier or other data that identifies a player, it is personal data and subject to DPDPA.
Can games use behavioural data to target in-game offers to children?
Section 9(3) bars tracking, behavioural monitoring and targeted advertising directed at children, subject to exemptions. Targeting offers based on a child's behaviour is high risk.
Tell us where your data sits.We'll show you where the exposure is.
A partner replies within one working day, with a first view on your penalty exposure.
Speak to a partner