By business type

Cookie Policy Generator for games

Written for player accounts, in-game purchases, chat moderation and the fact that a lot of players are children.

Generate your cookie policy Read the cookie policy guide

Games straddle two surfaces with different rules: a marketing website that runs ordinary web tracking, and a game client that uses SDKs and device identifiers instead of cookies. The document has to cover both without pretending the client is a website.

Games have the demographic problem no other consumer software shares at the same scale: a substantial share of players are children, and the ones who are not usually cannot be distinguished from the ones who are without asking. That single fact drives COPPA, the UK Age Appropriate Design Code, and the restrictions on advertising to minors.

The data itself is broader than most teams expect. Device identifiers, play sessions, purchase history, chat logs, voice communications, matchmaking telemetry and anti-cheat data - the last two of which collect at a depth that would be alarming in any other product category.

Monetisation adds regulatory attention. Loot boxes, virtual currency and in-app purchases are under active scrutiny across several jurisdictions, and disclosure requirements around odds, pricing and consumer rights are tightening.

What a cookie policy for a game or gaming platform has to cover

Marketing site cookies, including advertising and attribution tags
In-client SDK identifiers and telemetry, which are not cookies but are the same disclosure question
Age-aware behaviour: what is disabled for accounts that may belong to children
Store and platform-holder tracking that runs alongside your own
How consent is captured on the site and how identifiers are reset in the client

How a game or gaming platform actually moves personal data

Player accounts and progression

Identity, progress, inventory and achievements, usually linked to a platform account as well as your own.

Chat and voice communications

Text and voice retained for moderation, sometimes transcribed and analysed automatically.

Anti-cheat telemetry

Process lists, driver information and behavioural signals collected from the player’s machine at a depth that requires clear disclosure.

Matchmaking and behavioural scoring

Skill and behaviour ratings that determine who a player is matched with, which is profiling.

In-game purchases and virtual currency

Purchase history and balances, often through a platform holder rather than directly.

Advertising and attribution SDKs

In free-to-play titles especially, with restrictions where players may be children.

Third parties the draft will ask you about

Steam, PlayStation Network or Xbox Live · Unity or Unreal services · Easy Anti-Cheat or BattlEye · Vivox or Discord · AppsFlyer · AWS or Google Cloud · Stripe or platform billing

The rules that apply

Children’s privacy regimes

COPPA for under-13s in the US, the Age Appropriate Design Code in the UK, and digital age of consent rules across the EU - each with a different threshold.

Anti-cheat data collection

Kernel-level and behavioural anti-cheat collects deeply from the player’s device, which needs unusually specific disclosure.

Chat and voice moderation

Recording, retaining and analysing player communications for safety, which is processing with its own basis and retention.

Virtual currency and loot boxes

Disclosure requirements on odds and pricing, with several jurisdictions restricting or banning specific mechanics.

Platform holder requirements

Console and store certification imposes its own privacy and safety requirements beyond the law.

What the generated cookie policy contains

What the technologies actually are
Cookies, local storage, session storage, pixels, SDKs and server-side tags - the law covers storage and access on a device, not the word "cookie".
A per-cookie table
Name, provider, purpose, category and duration for each cookie, which is the format UK and EU regulators expect to see.
Category definitions
Strictly necessary, functional, analytics and advertising, with an honest explanation of why only the first runs without consent.
How consent was obtained and how to change it
The banner, the granular choices, and a permanent link to reopen preferences - the withdrawal route has to be as easy as the acceptance route.
Third-party cookies and onward use
Which providers set cookies through your site and what they do with the data once it is theirs.
Browser and device controls
Practical instructions, plus a note that blocking strictly necessary cookies will break parts of the service.

Games compliance essentials

Build a market-aware age gate
The threshold differs by jurisdiction, and a single number is wrong somewhere.
Write anti-cheat its own disclosure
What it reads, when it runs, and what leaves the machine.
Set chat and voice retention
Long enough for moderation and appeals, no longer.
Disable behavioural advertising for under-age accounts
And describe how age status is determined.
Publish loot box odds where mechanics involve chance
And keep the disclosure with the purchase, not buried.
Apply high-privacy defaults for child accounts
Including visibility, communications and data sharing.

Where this usually goes wrong

No age gate in a game children obviously play

The regulator’s test is whether the service is likely to be accessed by children, not whether you intended it.

Anti-cheat described in one vague line

It collects more deeply than anything else in the product and deserves a paragraph of its own.

Chat logs retained indefinitely

Moderation is a valid purpose with a finite useful life.

Behavioural advertising to under-age players

Restricted or prohibited under COPPA, the design code and several other regimes.

Loot box odds undisclosed

Increasingly a legal requirement rather than a platform courtesy.

High-privacy defaults not applied

The design code expects them for children, and defaults are the first thing tested.

Frequently asked questions

Does my game need an age gate?

If it is likely to be accessed by children, yes - and that is the regulator’s test rather than your intended audience. Thresholds differ by market, so a single global number will be wrong somewhere.

How should I disclose anti-cheat?

In its own section, describing what it reads from the device, when it runs, what leaves the machine and how long it is kept. It is the deepest collection in most games and a one-line mention is not adequate.

Can I show ads in a free-to-play game?

Contextual advertising generally yes; behavioural advertising to players who may be children is restricted or prohibited under COPPA, the Age Appropriate Design Code and other regimes.

Do I have to publish loot box odds?

In a growing number of jurisdictions and on several platforms, yes. Even where not strictly required, undisclosed odds attract consumer protection attention.

Do I need a cookie policy as well as a privacy policy?

In the UK and EU, yes in practice. PECR and the ePrivacy Directive regulate storing and reading information on a device separately from GDPR’s rules on processing, and the per-cookie disclosure is too detailed to bury in a privacy policy.

Do analytics cookies need consent?

In the UK and EU, yes - the ICO has said repeatedly that analytics is not "strictly necessary". Some EU regulators allow a narrow exemption for first-party, non-shared audience measurement, but the default answer is consent first.

Does a cookie policy need updating when I add a tool?

Yes, and this is the clause that goes stale fastest. Every new tag, pixel or embedded widget adds cookies your table does not list. Scanning your own site on a schedule is the only reliable way to keep it honest.

What about cookies set by embedded video and maps?

They count. An embedded YouTube player or Google Map sets third-party cookies as soon as it loads, so either it loads only after consent, or you use a privacy-preserving embed mode and say so.