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6 top tips for game developers to adapt to App Store and regulatory changes | Pocket Gamer.biz

Oscar Clark is the Chief Strategy Officer at Fundamentally Games.

2021 has seen some unprecedented events and I am not even talking about the pandemic.

The privacy and protection of children playing games has become an important issue for the games industry, in part due to the increasing awareness and concern of the general public about the negative aspects that have emerged from online experiences and social platforms.

Games have always been the target of certain groups, but we have to acknowledge that these changes were, at least in part, the result of some unfortunate (arguably cynical in some cases) design choices.

I’d like to take a look at three specific areas of change and our thoughts on what game developers can do about it and how we can deliver amazing experiences to gamers of all ages through authentic implementation.

1. What impact did iOS 14.5 have?

At the beginning of the year Apple removed its ID for advertisers (IDFA) after a lengthy change phase and replaced it with its SKAdNetwork / ATT approach.

This required a much more explicit opt-in process that users had to follow in order to track advertising data.

Predictably, ad spend and ad performance have declined significantly since the launch of iOS 14.5 (and later iOS 14.6), which can be seen in this graph (source: Tenjin), which shows a gradual decline as adoption increases.

Also, these issues don’t seem to have gone away, but seem to have migrated to Android (Source: Singular)

The more worrying aspect for me as a game publisher is the reported low approval rate; with roughly 20% of users saying ‘yes’ to the ATT prompt.

2. ICO and age-appropriate design code

In the UK, the Information Commission Office (ICO) has introduced its guidelines for collecting data in online experiences (not just games) based on the requirements of the GDPR and these are now in effect.

This applies to any games (or potential websites or apps) offered to anyone in the UK.

The ICO has set out 15 key principles that have placed some subtle but profound restrictions on how we should go about using data, especially in the best interests of the child.

The obligations of the Code mean that we must pay increasing attention to every aspect of the data that is collected about a player.


This extends the protection to young people up to the age of 18 and applies to all services that are likely to be used by this audience – even if this is not intended.

This change means we can no longer assume that a player is an adult just because we designed the game with that in mind. Instead, we must assume that it is not unless we can prove it.

The obligations under the Code also mean that we must pay increasing attention to every aspect of the data collected about a player on all platforms we work with.

For example, even if you’re working with a GDPR-compliant platform, you need to be very careful to understand how that platform collects and manages anonymous IDs to avoid custom events that you accidentally create make that player identifiable – and conflicted with the code.

Every team that offers games in the UK is required to conduct a privacy impact assessment and decide what level of risk they wish to accept.

While these limitations have ramifications, they actually provide a great setting for games to enhance their authentic interaction with players and build trust with your audience.

Advertising Standards Authority – How to Make In-Game Purchases

In addition to the regulatory framework that developers in the UK must consider, the Advertising Standards Authority published its new guidelines on in-game purchases in September.

This is aimed at misleading promotions around the cost and content of in-game purchases on in-game stores, platforms, or more general advertising. In particular, it seems to me that much of this is targeting the use of purchasable virtual currency and loot boxes by “bad actors”, which has caused so much backlash.

There are elements in the text of the directive that give me cause for concern about the implications for a real game design choice – but we must be aware that nuances are difficult to enact.

We need to see how these are put into practice before we make a judgment.

According to Tom Harding of Osbourne Clarke law firm, the key points are:

  • In-game purchase prices – Essential information must not be omitted or made illegible. Advertisers should ensure that the price of the digital currency is clearly stated and easily accessible or that it clearly states how much digital currency the player owns.
  • Odd pricing – Here, an in-game item costs less virtual currency than the smallest virtual currency package. For example, where a sword costs 50 gold but the lowest currency bundle costs 80 gold.
  • Methods that put players under undue pressure – For example, a short repetition timer with a request to buy a currency or a success through the purchase.
  • Random purchases of items – For example, direct or tacit suggestions that a rare / specific item will be granted for the next purchase.
  • Limited time offers – Such as for seasonal cosmetics and battle passes, which should not imply that items will only be available for a specific time, if the item is available again later, or more generally.

A very important distinction that I am very pleased about is that the Gambling Commission has stated that in their view, random loot boxes are not a gambling activity.

However, that does not mean that we can be satisfied with their use.

6 tips for game developers to customize

  1. Think about how to get your players to sign up for data (and ads!)
  2. Communicate the value of your game to your players in an authentic way – and design your monetization around this value. This includes explaining why you are collecting data and asking for permission.
  3. Build more integrated UA campaigns that combine the creative design with the desired audience interests and consistently tell a story over time across all of your marketing channels (* including in-game and live operations).
  4. Carefully separate your telemetry data from any gamer-specific information required to manage your game with session-based IDs. Make sure you can’t accidentally identify players through poorly thought out custom events.
  5. Use this telemetry to define cohorts based on the “life stages” of the players to track engagement and inform your user acquisition as well as live operations.
  6. Create a data card that shows what information is stored on which platform / tool and how it is used. The following is an example we created for a fictional game specifically aimed at a child audience on mobile devices:

All of these rules, codes, and guidelines provide a framework for developers to consider when developing and releasing games.

They place high levels of expectation on game teams in order to communicate and provide authentic value to the players. We should do that anyway, especially when it comes to games for children.
There are some tradeoffs to accept in game development, but in doing so we will be creating commercial content that not only will players love, but in a way that they can trust. Not only is this something we should be doing anyway, but it also makes economic sense in the long term.

If you want to know more, Oscar is hosting a webinar on the topic on Tuesday, October 26th. Please visit https://gameregulation.eventbrite.co.uk for more information

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