The FTC announced today that it reached a settlement with mobile ad network InMobi. InMobi offers a software-development kit (SDK) that its third-party app-developer customers can integrate into their mobile applications. The SDK allows InMobi to target advertisements to app users based on data collected and allows the app developer to thereby better monetize its advertising … Continue Reading
The Children’s Advertising Review Unit of the Council of Better Business Bureaus (“CARU”) routinely monitors web sites and mobile apps for compliance with its Guidelines and the Children’s Online Privacy Protection Act (“COPPA”). Through that routine monitoring, CARU recently discovered the information practices of the 1st through 7th grade mobile applications called Friendzy (e.g., 1st … Continue Reading
There was a lot of legislative movement for the educational technology (ed-tech) industry in 2015 with states placing additional privacy regulations on the industry, and the effects of those new acts should be felt this year. The states that passed this type of legislation in 2015 were following California’s lead. California’s governor signed the Student … Continue Reading
This week, the FTC announced settlements with two developers of children’s apps that it claimed had failed to comply the Children’s Online Privacy Protection Act (“COPPA”). While any COPPA enforcement by the FTC is noteworthy, these cases are particularly interesting in that they are the FTC’s first COPPA enforcement actions that are based on allegations that a child-directed online service … Continue Reading
Recent reports indicate that Google is developing a program that would allow children under the age of 13 to obtain accounts on Google services such as Gmail and YouTube. The Wall Street Journal recently reported that “Google is trying to establish a new system that lets parents set up accounts for their kids, control how … Continue Reading
Yesterday, the FTC gave its blessing to some new ways that covered organizations can obtain verifiable parental consent before collecting personal information from children under 13. The updated COPPA Rule FAQs offer expanded options to get consent using payment card information and for developers using a third party such as an app store to get … Continue Reading
A new California statute, which originated as SB 568 and will be codified as § 22580 et seq. of the Cal. Bus. & Prof. Code, takes effect January 1, 2015. The law has two key provisions: one addressing online advertising in connection with minors, which this post addresses, and one addressing a minor’s right to delete … Continue Reading
A new California statute, which originated as SB 568 and will be codified as § 22580 et seq. of the Cal. Bus. & Prof Code, takes effect January 1, 2015. Given the time it may take some sites, applications and online services to determine and implement appropriate compliance steps, now is the time to start considering … Continue Reading
The Children’s Advertising Review Unit of the Council of Better Business Bureaus (CARU) routinely monitors advertising to children. Through those monitoring efforts, CARU brings challenges against advertisers for alleged non-compliance with its Self-Regulatory Program for Children’s Advertising and the Children’s Online Privacy Protection Act (COPPA). In a recent case published on March 10, 2014, CARU … Continue Reading
On December 23, 2013, the Federal Trade Commission (“FTC”) issued a letter approving the use of knowledge-based authentication as a method of obtaining prior verifiable parental consent under its new Children’s Online Privacy Protection Act (“COPPA”) Rule, 16 C.F.R. Part 312 (“Amended Rule”). The Amended Rule not only expanded the non-exhaustive list of acceptable methods … Continue Reading
By Justine Young Gottshall And Damien Wint As we approach six months since the Federal Trade Commission’s (FTC) amendments to the Children’s Online Privacy Protection Act (COPPA) Rule, 16 C.F.R. Part 312 (the “Rule” or, as amended, the “Amended Rule”) became effective, it is essential that any website or online service that is not in … Continue Reading
For operators of web sites, apps and other online services, change is definitely coming – and quickly. On April 25, 2013, the Federal Trade Commission (“FTC”) issued updated Frequently Asked Questions (the “FAQs”) for its amended implementing rule (the “Rule”) for the Children’s Online Privacy Protection Act (“COPPA”). The FAQs give some additional insight regarding … Continue Reading
The FTC announced that it had finalized amendments to the Children’s Online Privacy Protection Act (COPPA) Rule, which the FTC originally enacted in 2000. The original Rule was created with the goal of protecting the online privacy of Children younger than the age of 13 (“Children”) by requiring that websites: 1) obtain parental consent before … Continue Reading
On December 10, 2012, the FTC released a follow-up to its February 2012 report on mobile apps for kids. The February 2012 report found that little or no information was available to parents about the privacy practices of the mobile apps the FTC surveyed on Apple’s App Store and Google’s Android Market. The FTC’s follow-up report finds … Continue Reading
Last week, the Federal Trade Commission (“FTC”) reached a settlement with Artist Arena LLC (“Artist Arena”), a company that operates pop star fan websites targeting the Tween set. In the complaint against Artist Arena, the FTC alleged that Artist Arena violated the Children’s Online Privacy Protection Act Rule (“COPPA Rule”) by failing to provide notice … Continue Reading
Co-Authored by Shannon Harell Yesterday, the Federal Trade Commission (“FTC”) released aFederal Register notice (“Notice”) seeking public comments on additional proposed revisions to the Children’s Online Privacy Protection Act Rule (“COPPA Rule”). As we blogged in September 2011, the FTC initially issued proposed revisions to the COPPA Rule and requested comments on September 15, 2011 (“2011 Notice”). The … Continue Reading
Today, the FTC released a report titled Mobile Apps for Kids: Current Privacy Disclosures Are Dis appointing. The FTC surveyed apps for children available in the Android Market and the Apple App store. The FTC found that apps can capture a bunch of information from a device and person, but there is a lack of information about data … Continue Reading
If you haven’t noticed, the FTC has had a monster year announcing or significantly moving forward various reviews of long-standing FTC interpretations, rules and guides. According to a report issued by the FTC in September of this year, the FTC is accelerating its typical 10-year review cycle for a number of rules and guides, in … Continue Reading
On September 15, 2011 the FTC issued proposed revisions to the Children’s Online Privacy Protection Rule (the “COPPA Rule”), which imposes requirements on web sites that are directed at and/or collect personal information from children younger than 13 years old. According to the FTC, the revisions are to “ensure that the Rule continues to protect … Continue Reading
If there really was any remaining debate over whether the Children’s Online Privacy Protection Act (“COPPA”) applies in the mobile world, this should put it to rest. W3 Innovations, LLC, doing business as Broken Thumbs Apps, along with the company president and owner Justin Maples, has paid $50,000 to settle an FTC complaint that certain mobile … Continue Reading
On May 12, 2011, the Federal Trade Commission announced that the operators of 20 online virtual worlds have agreed to pay $3 million to settle charges that they violated the Children's Online Privacy Protection (COPPA) Rule by collecting and disclosing personal information from hundreds of thousands of children under age 13 without their parents' prior consent. The FTC noted that this settlement is the largest civil penalty for a violation of the FTC's COPPA Rule.
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On November 30, 2010, the Federal Trade Commission announced a settlement with EchoMetrix, Inc. with respect to charges that the company failed to adequately disclose its privacy practices. EchoMetrix sells software that allows parents to monitor their children's online activities. The FTC alleged that the company engaged in a deceptive act or practice in violation of Section 5 of the FTC Act by failing to inform parents that the information the software collected about their children would be disclosed to third parties for marketing purposes.
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Social networking entails some risks and responsibilities. It may implicate privacy and labor law, confidentiality and nondisclosure agreements, advertising regulations, defamation, and other legal regimes, across borders in a global medium. Users, and their employers, need to be aware of these risks and responsibilities in deciding how to make best use of social media.
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This week, I will be providing short updates from the IAPP Global Privacy Summit in Washington, DC. The conference will be in full swing tomorrow, and I will report on various panels and topics of interest. In the meantime, as I prepare to see old and new friends at the Welcome Reception this evening, a few thoughts on what I expect to see and hear a lot over the next few days.
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