Pitfall 1: Silent Google Account linkage in privacy policy
Many developers disclose "achievements" and "leaderboard scores" generically without explaining that Google Play Games Services automatically links all data to the player's persistent Google account. This means player identity is not anonymous—it persists across sessions and games. GDPR Article 13 requires you to disclose the controller (you) and processor (Google LLC) separately. If your policy says "we store achievements" without naming Google as a processor or explaining account linkage, EU regulators will flag it as incomplete.
Consequence: DPA enforcement action, mandatory policy revision, potential fines under GDPR Article 83.
Pitfall 2: Missing or incomplete Data Processing Agreement
Google Play Games Services documentation often assumes developers will use standard Google Play terms, but GDPR Article 28(3) requires a written contract that explicitly defines what personal data Google processes, on whose instruction, and for how long. Many indie teams skip a formal DPA or assume Google's standard terms cover it. They don't—Google's master terms do not substitute for a GDPR-compliant processor agreement.
Consequence: You remain liable for unlawful processing. EU DPAs (especially Irish and German) have fined companies for missing Article 28 agreements even when the processor is compliant.
Pitfall 3: Ignoring COPPA social features
Leaderboards and friend connections in Google Play Games Services expose child identity. If you publish a game rated for ages 6+ or know children play, these features trigger COPPA. Many developers assume COPPA only applies to account creation; it also covers persistent identifiers (like Player IDs) and collection of persistent data (like friend lists).
Consequence: FTC enforcement (FTC Act Section 5), civil penalties up to $43,792 per violation, app removal from Play Store.