The FTC staff published today a “Six-Step Compliance Plan” for businesses to comply with the Children’s Online Privacy Protection Act (COPPA). The guidance, which provides a useful framework for businesses, states explicitly that COPPA applies to connected toys and other devices that collect personal information from children over the Internet. The FTC’s 2013 revisions to the COPPA Rule greatly expanded … Continue Reading
By Megan L. Rodgers What information is being collected by mobile apps and websites directed at kids? With whom is that information shared? What notice is provided to parents? Regulators in the U.S. and abroad continue to focus on these issues. The FTC recently released a follow-up report on privacy notices in mobile apps directed … Continue Reading
By Ani Gevorkian The FTC has issued a request for public comment regarding Riyo’s application to recognize a new proposed verifiable parental consent method under the FTC’s Children’s Online Privacy Protection Act Rule. The Rule, which implements the Children’s Online Privacy Protection Act (COPPA), requires certain website operators, mobile applications, and other online services to … Continue Reading
As part of our continuing coverage of the Congressional Privacy Bill, we provide below a deeper examination and explanation of Title II of the bill, the Do Not Track Kids Act of 2015. The Do Not Track Kids Act of 2015 amends the Children’s Online Privacy Protection Act (“COPPA”) by making its protections more expansive … Continue Reading
In late December 2014, the FTC staff sent China-based mobile app developer BabyBus a letter warning the company that several of its apps may violate the FTC’s Children’s Online Privacy Protection Act (COPPA) Rule. Staff alleged that the apps are marketed for young children and “use cartoon characters to teach children letters, counting, shapes, music, … Continue Reading
Making good on its warnings that mobile apps will be an enforcement priority under the revised Children’s Online Privacy Protection Act (“COPPA”) Rule, the FTC has announced two settlements with mobile app developers: TinyCo., the developer of several child-directed mobile apps, will pay $300,000 to settle charges that it violated COPPA by collecting children’s email addresses through its mobile app … Continue Reading
The FTC staff has posted revisions to three Frequently Asked Questions (“FAQs”) related to obtaining verifiable parental consent under its COPPA Rule. For a comparison of the old and new FAQs, click here. Although the changes (which include a new FAQ H.16) may appear substantial, they mostly reaffirm the FTC’s longstanding position that the agency’s … Continue Reading
Last weekend at South by Southwest (“SXSW”) Interactive, a panel promoted the notion that it is in fact possible to harmonize innovation with kids’ privacy in the app space, but that doing so involves “a lot of work.” In particular, the panel suggested that it takes a conscious desire on the part of app developers … Continue Reading
The FTC has denied AssertID’s request to recognize a new method for obtaining verifiable parental consent for the online collection, use, and disclosure of personal information from children under 13. The application was the first of its kind to be filed since the FTC added a voluntary parental consent approval process to its revised rule implementing … Continue Reading
The Federal Trade Commission (“FTC”) recently released an additional question and answer as part of its revised COPPA FAQs, which provide guidance on the FTC staff’s interpretations of the rule implementing the Children’s Online Privacy Protection Act (“COPPA”). As we previously reported, the FTC published substantial revisions to the COPPA FAQs in April in order … Continue Reading
The Federal Trade Commission has sent letters to more than 90 different companies who develop mobile apps that the FTC claims may be directed to children. The letters emphasize that the FTC has not evaluated the apps or the companies’ practices to determine if they comply with the current or revised COPPA Rule. Instead, the letters remind these … Continue Reading
The Federal Trade Commission has released its much anticipated revised COPPA FAQs. Although these FAQs are not legally binding, they provide informal guidance to industry on staff’s interpretations of the COPPA Rule. For the most part, the FAQs reiterate past guidance and emphasize key provisions of the new COPPA Rule and its Statement of Basis and Purpose. However, here are 5 key things that the revised … Continue Reading
Path, a social networking mobile app, has agreed to enter into a settlement with the Federal Trade Commission (“FTC”) regarding charges that the company deceived consumers by collecting contact information from users’ mobile address books without notice and consent. The agreement also resolves charges that the company violated the Children’s Online Privacy Protection Act (“COPPA”) … Continue Reading
Yesterday, two Federal Trade Commission (“FTC”) attorneys addressed several key issues raised by the Commissions’ revised final rule implementing the Children’s Online Privacy Protection Act (“COPPA”). Speaking at a webinar sponsored by the International Association of Privacy Professionals, Mamie Kresses and Phyllis Marcus, both senior attorneys at the FTC who focus on COPPA issues, discussed … Continue Reading
The U.S. took the lead in legislating privacy rights for children and parents in the Children’s Online Privacy Protection Act more than a decade ago. Now the European Union has proposed including privacy protections for children in the Data Protection Regulation under discussion, and Latin American countries have included regulation of children’s privacy in new … Continue Reading
The Federal Trade Commission has released its revised final rule implementing the Children’s Online Privacy Protection Act (“COPPA”), which governs (1) operators of websites and online services that are directed to children under the age of 13 and (2) operators of general audience websites or online services that have actual knowledge that a user is … Continue Reading
The Federal Trade Commission released today its second report on mobile apps directed to children. The report, which follows up on an analysis that staff conducted in February 2012, examined the privacy disclosures of hundreds of kid-directed mobile apps and tested the apps’ practices against these disclosures to determine if the disclosures were accurate and complete. Staff found the results … Continue Reading
Earlier today, the Federal Trade Commission announced a two-week extension for submitting comments on the FTC’s latest proposed revisions to the rule implementing the Children’s Online Privacy Protection Act (“COPPA”). In place of the original September 10, 2012, deadline, comments will now be accepted until September 24, 2012. The FTC granted the extension after sixteen … Continue Reading
By Lindsey Tonsager and Shel Abramson Earlier this morning, the FTC proposed additional revisions to the rule implementing the Children’s Online Privacy Protection Act (“COPPA”). COPPA governs the online collection, use, and disclosure of children’s personal information by (1) operators of websites and online services that are directed to children under the age of 13 … Continue Reading
The New Jersey Attorney General and Division of Consumer Affairs have announced a settlement with 24x7digital, the developer of the “TeachMe” mobile apps for preschool through second-grade children, to resolve claims that the company violated the federal Children’s Online Privacy Protection Act (“COPPA”). The state alleged that children were encouraged to submit their full names, along with a photograph, … Continue Reading
The FTC has decided not to pursue an enforcement action against Clearwater Aquarium for alleged violations of the Children’s Online Privacy Protection (“COPPA”) Rule. In February 2012, the Children’s Advertising Review Unit (“CARU”) referred the Clearwater Aquarium’s website to the FTC for review under COPPA after the Aquarium reportedly did not respond to CARU’s inquiry. CARU … Continue Reading
Over the last few weeks, a number of cosponsors have been added to the Do Not Track Kids Act of 2011 (H.R. 1895), bringing the total number of cosponsors to 29. The bill was introduced by Rep. Markey and Rep. Barton on May 13, 2011. Earlier this month, the two members also hosted a Congressional briefing to discuss how … Continue Reading
The FTC staff released a report today calling for participants in the mobile app ecosystem — including app developers, app stores, and third parties who collect data through mobile apps — to provide better privacy notices to parents about mobile apps directed to children, and warning that over the next six months, staff will be conducting additional reviews … Continue Reading
