CHILDREN
PROTECTED

COPPA · GDPR Art. 8 (under 16) · Non-personalized advertising · Parental channel

Children's Privacy

Last updated: May 2026 · Data Controller: Giovanni Picaro, Operator (Italy)

This page describes how Game Hub Arena addresses the privacy of users who are minors. Browser games are played by an audience that includes substantial numbers of users under 18, including users under 13 — this is a fundamental fact for any games portal and we treat child-safety considerations as a feature of the editorial scope rather than an afterthought. Frameworks applied: COPPA (Children's Online Privacy Protection Act, U.S., under-13); GDPR Article 8 (EU children's-consent threshold) applied at the conservative under-16 level uniformly; Italian D.Lgs. 196/2003 and the Garante DPA's guidance on minors and digital services.

1. The framing

The audience for an HTML5 games portal includes a meaningful portion of users under 18, with a non-trivial portion under 13. For some game categories (children's games, educational games), the audience is predominantly minor. Our framework treats this as a compliance and editorial-responsibility matter:

The Site does not target advertising specifically to children.

The Site does not collect personal information from children beyond what is essential for Site function.

The Site applies advertising-defaults that minimize personalized-advertising exposure for users we cannot reliably identify as adult.

The Site provides a parental-contact channel.

The Site applies categorical content exclusions (per Content Standards) that exclude content sexualizing minors and other inappropriate material, with NCMEC reporting framework where applicable.

2. COPPA compliance (U.S. users under 13)

The U.S. Children's Online Privacy Protection Act (COPPA, 15 U.S.C. §§ 6501-6506) applies to operators of websites and online services directed at children under 13, or operators with actual knowledge that they are collecting personal information from a child under 13.

Game Hub Arena's COPPA practices:

No user-account registration. The Site does not have accounts or signup flows that would collect personal information.

No directed children's marketing. The Site is a general-audience HTML5 games portal that includes children-appropriate games at the family-friendly default tier; not specifically directed at children below age 13.

Minimal data collection. Only what is automatically logged via Site visit (per Privacy Policy); no proactive collection of names, addresses, ages, or other personal information.

Advertising defaults to non-personalized for users we cannot reliably identify as adult. Non-personalized advertising serves contextual ads (based on the page content) rather than ads tailored to user profile.

Parental contact channel: privacy [at] gamehubarena [punto] fun. Parents who become aware that a child has interacted with the Site can request deletion of any data we hold.

No knowing collection of personal information from children under 13; if such collection occurs unintentionally (a minor email correspondent identifying themselves as such), the data is deleted upon notice.

3. GDPR Article 8 conservative threshold (EU users under 16)

Under EU GDPR Article 8, member states set the children's-consent threshold between 13 and 16. Italy and several other member states have adopted the conservative 16 threshold. Game Hub Arena applies the under-16 threshold uniformly across the EEA, irrespective of the user's specific member-state residence:

For users we cannot reliably identify as 16+, the lawful-basis framework for processing personal data either does not include legitimate-interest-based personalized advertising or requires verifiable parental consent.

The default for such users is non-personalized advertising and minimal data processing.

Where parental consent is asserted, verification is implemented to a reasonable level proportionate to the data sensitivity.

4. Advertising and minors

Google AdSense is the Site's advertising network. The relevant practices:

Non-personalized advertising as default for users we cannot reliably identify as adult. AdSense supports non-personalized configuration.

Category exclusions for inappropriate-for-minors content categories: gambling, adult, scam-products, and equivalent.

AdSense for Children's Content considerations where applicable.

Reports of inappropriate ads reaching minors: abuse [at] gamehubarena [punto] fun. We work with AdSense to investigate.

5. Game content exposure to minors

The catalog content rating framework (per Content Ratings) flags games intended for older audiences. The default catalog presentation is family-friendly. Higher-rated games are flagged. The framework is not a replacement for parental judgment but is intended to give parents and minor users the context to make informed choices. Categorical exclusions (per Content Standards) keep the catalog free of:

Content sexualizing minors.

Adult sexual content.

Real-money gambling games.

Games promoting real-world hatred against protected groups.

6. In-game purchases and minors

Some games in the catalog include in-game purchase mechanics (typically through the developer's framework). Where these mechanics are predatory (loot boxes for real money, pay-to-win that targets impulse purchase, unclear pricing), we evaluate whether the game should remain in the catalog. Where parents identify in-game purchase concerns affecting minor users:

Email privacy [at] gamehubarena [punto] fun with the game in question and the concern.

The catalog response may include rating-tier adjustment, mature-flag application, or game removal where the issue is severe.

For specific transaction disputes, the user / parent must contact the game's payment-handling provider; Game Hub Arena does not handle in-game-purchase transactions.

7. Parental concerns and contact channel

Parents who have concerns about a minor's interaction with the Site can contact privacy [at] gamehubarena [punto] fun. Common contact reasons:

Request to delete data collected from a minor.

Request to discuss a specific game's appropriateness or content rating.

Request to clarify what advertising the minor may have been exposed to.

Reports of inappropriate content the minor encountered.

In-game purchase concerns.

General questions about the Site's children's-privacy framework.

Response standard: parental concerns are expedited — typical response within 7 business days, faster for safety-related matters.

8. NCMEC reporting framework

Where the Site identifies content that constitutes child sexual abuse material (CSAM) or content that solicits or attempts to exploit minors, the Site reports to the U.S. National Center for Missing & Exploited Children (NCMEC) at report.cybertip.org and to applicable national law enforcement (in Italy, the Polizia Postale).

The catalog's Content Standards categorically exclude content sexualizing minors. Reports of any such content slipping through to abuse [at] gamehubarena [punto] fun are highest-priority response: immediate removal and reporting to NCMEC where applicable.