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Research Paper Volume 9 Issue 2 719 - 733 April 2, 2026

Data Privacy and User Protection in Digital Gaming Platforms: A Comparative Study Of India, USA, and UK

Lead author · Corresponding
Narayan Kumar Jha
Student at Law College Dehradun, Uttaranchal University, Dehradun, India
Co-author
Dr. Lakshmi Priya Vinjamuri
Professor at Law College Dehradun, Uttaranchal University, Dehradun, India
View PDF Full text DOIhttps://doij.org/10.10000/IJLMH.1111576
Abstract

The fast evolution of digital gaming platforms, covering mobile apps to fully immersive cloud, based environments, has led to increased worries about data privacy and user protection. In order to provide better experiences, these platforms repeatedly gather a wide range of personal data, which includes the users' behavioural patterns, geolocation data, biometrics, and financial details, and this is usually done without giving enough information about these activities. This paper compares the different laws relating to data privacy in India, the USA, the UK, and Australia and focuses on how these legal areas deal with the risks that arise from the modern gaming ecosystems. India’s Digital Personal Data Protection Act, 2023 is indicative of a developing privacy regime, whereas the USA is following a fragmented, sector, specific approach. The latter is mainly based on COPPA, CCPA, and FTC oversight. On the other hand, the UK is using a full GDPR, based model, and Australia is regulating through the Privacy Act 1988 and the Australian Privacy Principles with the addition of online, safety obligations. This research finds that different jurisdictions share and differ in aspects such as consent requirements, age, verification requirements, data, minimization standards, enforcement mechanisms, and protection from manipulative practices like loot boxes, targeted advertising, and dark patterns. Their analysis shows that the differences in child, protection safeguards, breach, notification mandates, and cross, border data transfer rules are so great that they lead to an uneven level of user protection between various regions. The article ends with suggestions for harmonizing policy approaches, increasing algorithmic transparency, providing more robust safeguards for minors, and elevating international cooperation to create a safer and privacy, respectful global gaming environment.

Type
Research Paper
Information
International Journal of Law Management and Humanities, Volume 9, Issue 2, Page 719 - 733
DOI: https://doij.org/10.10000/IJLMH.1111576
Creative Commons
CC BY-NC 4.0 This is an Open Access article distributed under the terms of the Creative Commons Attribution–NonCommercial 4.0 International (CC BY-NC 4.0) (https://creativecommons.org/licenses/by-nc/4.0/), which permits remixing, adapting, and building upon the work for non-commercial use, provided the original work is properly cited.
Copyright
Copyright © IJLMH 2026
Disclaimer
The views and opinions expressed in this manuscript are those of the author(s) alone and do not reflect the views, policies, or position of the Journal.

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