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Assume my game tracks some information about user behaviour e.g. using Google Analytics. The information includes:

  • how much time has the user already spent playing the game in total
  • how much time in this game session
  • how many actions of various types had the user already performed:
    • how many times the game was started
    • how many (and which) levels were completed
    • how many times some particular action was already performed by the user

None of these data contain any personal information, all of them are sent anonymously, without any user id identification.

Is a user consent required or expected for such analytics information?

I have read Legal restrictions if using Google Analytics on PC game?, but it does not seem to distinguish the situation for anonymous analytics vs. user tracking.

I have also read GA terms regarding privacy, but I am unsure what exactly it means for this particular use:

You must disclose the use of Google Analytics, and how it collects and processes data. This can be done by displaying a prominent link to the site “How Google uses information from sites or apps that use our services”, (located at www.google.com/policies/privacy/partners/, or any other URL that Google may provide from time to time). You will use commercially reasonable efforts to ensure that a User is provided with clear and comprehensive information about, and consents to, the storing and accessing of cookies or other information on the User’s device where such activity occurs in connection with the Service and where providing such information and obtaining such consent is required by law.

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