Mobile games: closure of the injunction issued against VOODOO

05 October 2023

By decision of July 13, 2023, the CNIL’s restricted committee closed the injunction issued on December 29, 2022, against VOODOO, publisher of mobile games.

Background information

On December 29, 2022, the CNIL's restricted committee imposed a fine of 3 million euros on VOODOO for using an essentially technical identifier ("identifier for vendors" or "IDFV") for advertising purposes, without the user's consent.

In addition to this fine, the restricted committee ordered the company to obtain the user's consent to the use of the IDFVQ for advertising purposes, within 3 months.

If the company failed to comply with this injunction, it was exposed to a fine of 20,000 euros per day of delay.

Closure of the injunction

Following the company's observations, the restricted committee considered that VOODOO had complied with the injunction issued in its deliberation of December 29, 2022, by presenting a window enabling user consent to be obtained when games are opened, within the time limit set. The restricted committee therefore decided to close the procedure on July 13, 2023.

This closure only concerns the scope of the injunction issued by the restricted committee in its deliberation of December 29, 2022. In fact, this closure decision does not prejudge the CNIL's analysis of the compliance of the new consent window implemented on the applications developed by the company with all the provisions of article 82 of the French Data Protection Act, in particular, the requirement to provide "clear and complete" information on the purposes pursued by the reading of the IDFV and on the means of objecting to this reading.

The CNIL therefore reserves the right to check the compliance of the applications with these other requirements and, if necessary, to mobilize the entire repressive procedure.