PRIVO Case Study


PlaytestCloud connects mobile game developers with targeted groups of users to remotely test games in development.

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PlaytestCloud is a platform that connects mobile game developers with targeted groups of users to remotely test and provide feedback on games in different stages of development.

This model not only provides valuable feedback to developers seeking to improve their games by observing players' experiences, but also encourages community-driven progress in the gaming industry.

The Challenge

Given that kids enjoy playing games just as much as, if arguably not more than, adults, PlaytestCloud decided to expand their playtester panel to include kid testers. The team encountered a number of challenges in designing an effective unmoderated playtesting experience for children, which included understanding and complying with global child privacy laws.
The Children's Online Privacy Protection Act (COPPA) in the United States and the General Data Protection Regulation (GDPR) in the European Union, widely considered the most influential policies, seek to promote and ensure special privacy protections for children, recognizing their particular vulnerabilities to harm and exploitation online. COPPA requires operators of websites and online services to obtain verifiable parental consent prior to collecting the personal information of children ages 12 or under. COPPA also provides parents with the rights to access, correct, delete, and prevent further collection or use of their child's personal information, and imposes data minimization and retention requirements. GDPR requires online service providers to obtain verifiable parental consent prior to processing the personal information of children ages 15 or under, which may be lowered to 12 or under, depending on the Member State. GDPR also ensures children possess the same rights as adults, including the rights to access, correct, and delete their personal information.
Faced with the complexity of navigating child privacy laws across jurisdictions, PlaytestCloud turned to PRIVO for support in developing and certifying a COPPA and GDPR-compliant solution for including kid playtesters.
Playtest Challenge-02
Playtest Solution-01

The Solution

PlaytestCloud obtains verifiable parental consent by allowing adult playtesters to add children to their account as kid playtesters. The parent facilitates all interactions with the child, ensuring the parent is in control and receives notice and provides consent prior to the collection, use, or disclosure of their child's personal information. To prevent users ages 15 or under from creating accounts, PlaytestCloud implements a neutral, locked age screen in the registration form.
PlaytestCloud verifies the parent when a user creates a child tester profile. To add their child as a kid playtester, the parent provides only their child's name, gender, date of birth, and favorite games. PRIVO’s adult verification widget then verifies the parent is an adult through their Social Security Number, PayPal, credit card, driver's license, print and sign form, or phone call. Methods are approved by the Federal Trade Commission as sufficient to provide full verifiable parental consent under COPPA.
PlaytestCloud chose to outsource verification after considering the cost and risk of processing and securely storing more sensitive personal information than necessary for their core service of playtesting. This adherence to the principle of data minimization also applies to the types of personal information collected from children, only collecting and retaining that which is necessary for the provision of their services. PlaytestCloud uses the child's gender, date of birth, and favorite games to curate appropriate games for playtesting, and only shares their gender, age, favorite games, gameplay, and audio recordings with the game developers. 
After verifying the parent’s account, the parent receives an email from PlaytestCloud with direct notice of the types of personal information collected from their child, a link to the privacy notice, and contact information to opt out of or delete the parent’s account and the child’s information. Users may also contact PlaytestCloud to withdraw consent, object to or restrict data processing, access, verify, rectify, delete, or transfer their data, and lodge a complaint. PlaytestCloud expects parents to supervise their children while playtesting and employs an additional layer of protection and reliability by carefully reviewing the gameplay and voice recordings for quality and safety.

A Bonus Challenge

Game developers approached PlaytestCloud with another challenge to tackle – conducting post-playtest surveys and interviews with children to gather more in-depth insight into kid playtesters' experiences and preferences. In efforts to offer surveys and interviews compliantly, PlaytestCloud again consulted with PRIVO to understand the regulatory requirements and develop a workable process.
Before administering these post-playtest surveys and interviews, PlaytestCloud needed to establish a process for screening questions, informing the parent, obtain parental consent, and determine how the interviews would be conducted, what information from the interviews would be shared, and with whom.

A Bonus Solution

PlaytestCloud introduced post-playtest interviews for kid playtesters through a playtest invitation email to the parent, where the parent is informed of the survey or interview. The email includes what information will be collected from their child, how the information will be used and shared, how the parent can request deletion of the information, and instructions on how to opt their child in to the survey or interview.

For interviews, the kid playtester participates in a recorded video interview conducted by the game developer with the parent present. The video recordings are shared with and used by the game developer to gather feedback to improve the game, and may be shared with other parties for research purposes. For surveys, PlaytestCloud provides the parent with a link to complete a post-playtest survey in the playtest invitation email, and informs the parent that the survey results will be shared with the game developer.
Throughout the process, PlaytestCloud keeps parents informed and involved, obtaining consent prior to collecting, using, or sharing personal information from children.

In Conclusion

The idea of encouraging co-gaming with children counters the popular refrain that all screen time impairs healthy cognitive, emotional, and physical development. Rather, co-gaming – parents and children playing games together – is considered a helpful relational tool to strengthen bonds and promote discussions.

PlaytestCloud's model for including kid playtesters not only ensures children are protected from the risks involved from personal information collection, use, and disclosure, but also encourages building a positive relationship between parents and their children with regards to gaming.



See the Parent Verification Process In-Action


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