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COPPA compliance for a simple single-player RPG

Discussion in 'Unity Analytics' started by ModLunar, Aug 7, 2019.

  1. ModLunar

    ModLunar

    Joined:
    Oct 16, 2016
    Posts:
    87
    I'd just like to be extra-sure about this: So I am developing a single-player game. It's an anime-style RPG where you can go through dungeons to defeat enemies, collect loot and money, level up and unlock new dungeons and items.

    The game sends and receives absolutely zero data over the network. It does not collect any information about the user, other than in-game data into game save files on the local computer under Application.persistentDataPath. (For example, you've reached Lv. 3 with 40/42 HP, 0 items in their ItemInventory, etc.).

    I want to start using Unity Analytics to analyze how my game is played, and would like to have my game open and available for all ages (and thus, this requires COPPA compliance). So, I have enabled Unity Analytics for the project, and have set the following option to true in Unity: "This app is primarily targeted to children under age 13."

    I've been reading through the manual on Unity Analytics, and have come across this page, concerned with COPPA, that describes roughly what kind of data Unity Analytics collects, and how it is used. In the 3rd paragraph, it describes how an anonymized user ID is generated for each user in my game. This should be no problem with COPPA, I believe, since it is anonymized, please correct me if I am wrong (thank you in advance!). However, it then says the following at the end of that 3rd paragraph:

    Should I be concerned about this violating COPPA, or is this legally safe usage of the data? I am mostly concerned with Unity Analytics here, without me writing any code yet to send custom events or record any custom data with Unity Analytics. I'll probably be asking about that in a separate thread/question at a later date.

    Thanks a lot for taking the time to read this and help! It means a lot to me, because this will be my first released game, and I really love game development.
     
  2. ap-unity

    ap-unity

    Unity Technologies

    Joined:
    Aug 3, 2016
    Posts:
    1,203
    @ModLunar

    Unfortunately, we won't be able to provide much guidance on legal questions. I would encourage you to seek your own legal counsel.

    I can only reiterate what's in the COPPA page in the manual:
     
  3. ModLunar

    ModLunar

    Joined:
    Oct 16, 2016
    Posts:
    87
    @ap-unity Ah, I gotcha. It's probably tough for you to have to say that, and I thank you for your help anyway!