Data Privacy & Protection of Minors
Advice on personal information, third-party SDKs, children’s data and cross-border transfers, including Chinese requirements relevant to game services.
Service Overview
Data protection compliance for games goes beyond drafting a privacy policy. It requires a clear understanding of what data a game collects, which features and third-party components collect it, who uses it, where it is transferred, and how long it is retained.
Processing data relating to real-name verification, device identifiers, payment records, voice chat, advertising attribution, and anti-cheat functions may involve sensitive personal information or affect the rights and interests of minors.
We advise on the requirements that apply to the game and its operations in China. Our review identifies the issues that arise on the facts and the steps available to address them; it is not a certification that every applicable requirement has been met.
Scope of Services
Data Inventory & Privacy Documentation: We map the personal information a game collects and uses, the purposes of processing, retention periods, and data flows. We help improve privacy policies, consent mechanisms, account closure procedures, and processes for handling users' requests to exercise their data protection rights.
SDK & Vendor Management: We review how third-party advertising, analytics, attribution, payment, and cloud service providers process personal information, including through SDKs and other components. We also review related privacy disclosures and the allocation of responsibilities and liability in service agreements.
Sensitive Personal Information & the Protection of Minors: We advise on the processing of identity information used for real-name verification, payment information, voice data, location data, and biometric information. We help improve age assurance measures, parental or guardian consent mechanisms, anti-addiction measures, and safeguards enabled by default for minors.
Outbound Data Transfers & Incident Response: We assess applicable local data storage and cross-border transfer requirements based on actual data flows. We also provide legal support for data breach response and remediation, including reporting to regulators and notifying affected users where required.