DATA | Can my game collect data from players to improve AI systems? – Developer Portal - Support

Developers may collect gameplay and analytics data to understand how their games are used and to improve game features. In some cases, this data may be used to improve systems that rely on machine learning or artificial intelligence (AI).

When collecting or using player data for these purposes, 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 be used to improve AI systems?

Developers may analyze gameplay data generated while players interact with their game. This may include:

• gameplay events and interaction data
• player progression or performance metrics
• feature usage and gameplay patterns
• system performance or diagnostic information

Some of this information may be anonymous gameplay telemetry, while other data may qualify as personal data depending on how it is collected and processed.

Do developers need to tell players that data is being collected?

Developers are responsible for providing players with clear privacy disclosures describing how player data is collected and used.

Where player data is collected to improve gameplay systems, analytics, or AI-related features, developers should ensure that this use is accurately described in their privacy policy or player disclosures.

What if the data includes personal data?

If gameplay or analytics data includes personal data, developers must comply with applicable data protection laws.

Depending on the jurisdiction and the way the data is processed, developers may need to:

• provide appropriate privacy notices to players
• establish a valid legal basis for processing personal data
• implement appropriate security and data protection measures

Additional requirements may apply under laws such as GDPR, UK GDPR, and other regional privacy frameworks.

Does the Data Processing Addendum (DPA) apply to this data?

Yes. The Data Processing Addendum (DPA) forms part of the Upload Agreement and governs the processing of personal data in connection with the Kongregate platform.

If player data processed through the game qualifies as personal data under applicable law, developers must ensure that their use of that data is consistent with the obligations described in the DPA.

Can developers use player data to train external AI systems?

Developers should only use player data in ways that are:

• consistent with their player disclosures and privacy policy
• compliant with applicable privacy laws
• consistent with the Game License & Upload Agreement and the DPA

Developers should review their legal obligations carefully before using player data to train external AI systems.

Does Kongregate use player gameplay data to improve 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.

Such use does not transfer ownership of the developer’s game or intellectual property.