Developers may use gameplay data and analytics to improve their games, including developing or improving systems that rely on machine learning or artificial intelligence (AI).
However, when using gameplay data or player data, developers must ensure that their data practices comply with the Game License & Upload Agreement, the Data Processing Addendum (DPA), and applicable privacy laws.
What types of data might developers use for AI systems?
Developers may collect and analyze different types of information generated through gameplay, such as:
• gameplay events and performance metrics
• player behavior patterns
• game progression data
• system performance or debugging data
Some of this data may be anonymous gameplay telemetry, while other data may qualify as personal data depending on how it is collected and used.
Does the Game License & Upload Agreement allow developers to train their own AI systems?
The Game License & Upload Agreement does not prohibit developers from using their own game data to develop or improve systems related to their games.
However, developers remain responsible for ensuring that any use of player or gameplay data:
• complies with applicable data protection laws
• is consistent with the developer’s own privacy policy
• complies with the requirements of the Data Processing Addendum (DPA), where applicable
What if the data includes personal data?
If gameplay or telemetry data includes personal data, additional legal requirements may apply.
Depending on the jurisdiction and how the data is used, developers may need to:
• provide appropriate privacy disclosures to players
• ensure a valid legal basis for processing the data
• implement appropriate data protection and security measures
The DPA provides additional rules regarding the processing of personal data in connection with the Kongregate platform.
Can developers use Kongregate platform data to train AI models?
Developers should only use data that they are authorized to collect and use.
If developers intend to use gameplay or player data to train AI systems, they should ensure that doing so:
• complies with the Game License & Upload Agreement
• complies with the Data Processing Addendum (DPA)
• is consistent with their own player privacy disclosures
Developers should not assume that all platform-related data may be used for AI training without reviewing these obligations.
Does Kongregate use gameplay data to train AI systems?
As described in the Game License & Upload Agreement, Kongregate may use anonymized or aggregated platform and gameplay data to improve the Kongregate platform and related services, including AI/ML systems.
This use does not transfer ownership of the developer’s game or underlying intellectual property.
Where can developers learn more about data protection requirements?
Developers may find the following resources helpful:
European Data Protection Board (EDPB)
https://www.edpb.europa.eu
U.S. Federal Trade Commission – Privacy Guidance
https://www.ftc.gov/privacy
UK Information Commissioner’s Office (ICO)
https://ico.org.uk
OECD AI Principles
https://oecd.ai/en/ai-principles
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