DESIGNING A FREEMIUM GAME

- LEGAL PERSPECTIVE

Hannu Partanen Legal Counsel, Fondia

FREEMIUM?

CC BY-SA 2.0 author ugocuesta

HOW TO COMPLY?

RECENT DEVELOPMENT • Major F2P success through adoption of mobile and

tablets

• OFT Principles for online and app-based games (1/2014)

• EU Commission’s Stakeholder Consultation (2/2014)

• Italy investigating major players for unfair commercial practices in F2P (5/2014)

• Industry best practices? (2014?)

• New EU privacy regulation? (2015?)

CC BY-SA 2.0 author sankarshan

GAMES ADVERTISED AS “FREE” SHOULD

NOT MISLEAD ABOUT THE TRUE COSTS

INVOLVED

PROVIDE CLEAR INFORMATION • Associated costs provided upfront, accurately & clearly

• What do users get in exchange?

• Note: before vs. during gameplay

• Clear differentiation between commercial messages and gameplay

• Contact information must be available

CC BY 2.0 author Paolo Camera

FREE!

CC BY 2.0 author JD Hancock

FREE!

CC BY 2.0 author kdinuraj

NO DIRECT EXHORTATIONS TO

CHILDREN TO BUY OR TO PERSUADE AN

ADULT TO BUY FOR THEM

PURCHASES SHOULD NOT BE DEBITED

BY DEFAULT WITHOUT EXPLICIT CONSENT

Boom Beach by Supercell

92% HAD CONCERNS ABOUT HOW PRIVACY

INFO IS PRESENTED 54% HAD NO PRIVACY

POLICY AT ALL Mobile apps in GPEN International Privacy Sweep 2013

“APP DEVELOPERS NEED TO BE

TRANSPARENT AND OFFER CLEAR, EASY-

TO-UNDERSTAND PRIVACY INFO”

Chantal Bernier, Interim Privacy Commissioner

of Canada

SONY FINED £250,000 AFTER MILLIONS OF

UK GAMERS’ DETAILS COMPROMISED

(ICO.ORG.UK 2013)

QUESTIONS?

Hannu Partanen Legal Counsel, Fondia

hannu.partanen@fondia.fi

@hannupartanen