By business type

Refund 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 refund policy Read the refund policy guide

Game refunds are mostly not yours to give. Steam, PlayStation, Xbox, the App Store and Google Play each run their own refund regime as merchant of record, and the policy’s job is to describe that accurately rather than promise something you cannot execute.

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 refund policy for a game or gaming platform has to cover

Which storefront processes refunds for each platform you ship on
Consumer cancellation rights and the digital-content waiver taken at purchase
Virtual currency and in-game items: what is refundable and what is not
Refunds where the service is discontinued, including unspent balances
Your own goodwill position for direct sales, kept separate from platform rules

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 refund policy contains

The statutory right, stated separately
Consumer cancellation rights exist whatever your policy says, so they are set out first and your goodwill terms second.
Time limits and how they are counted
When the clock starts, whether it runs in calendar or working days, and what stops it.
Condition and evidence requirements
What state goods must come back in, and what proof of purchase you accept.
Who pays return postage
Split between faulty and change-of-mind returns, because the law treats them differently.
Refund method and timing
Original payment method, and the deadline you commit to once goods or notice are received.
Exclusions, stated lawfully
Perishables, personalised goods, unsealed hygiene items and downloaded digital content - the exclusions the law actually permits.

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.

Can I run a no-refunds policy?

Not against statutory rights. In the UK and EU a consumer’s cancellation and faulty-goods rights apply regardless of what your policy says, and advertising "no refunds" is itself treated as a misleading practice.

Do digital products have to be refundable?

The cancellation right can be waived for digital content, but only if the customer gave express consent to immediate delivery and acknowledged losing the right. That acknowledgement has to be captured at checkout, not assumed.

How long do I have to issue a refund?

In the UK and EU, within 14 days of receiving the goods back or of the customer proving they returned them. Card scheme rules and marketplace policies often impose something tighter.