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philpo ,

Nope, doesn't work that way. The game dev is offering a networked service (community,support,etc.)in his name/trademark/brand and therefore is therefore liable for the data protection, it doesn't matter at all if the dev is the data holder or not - that's up to the dev to manage contractually with discord.

The concept of "not holding the data, not liable for the data" has been turned down by various high court rulings by now - Amazon and Microsoft amongst others have tried it and lost.

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