Child privacy while playing with apps is something to consider. The Federal Trade Commission (FTC) has been concerned. The aspect of how information, that is children’s personal information, is shared with advertisers and the related networks brings to mind the requirements of the Children Online Privacy Protection Act (COPPA).
In 2013, the FTC amended the Act to include in the Rule the definition of ‘personal information’. The FTC has been made aware that specific advertising was directed to children. The FTC found that these third-party entities were advertising to children using ‘identifiers’ that strategically marketed to children. The identifiers would link to the internet protocol of the child’s device being used which then provided advertising tailored to the child.
In pursuing legal action against app developers, the FTC argued that the thirty-party network advertisers using persistent identifiers were collecting personal information of the children. Furthermore, the FTC asserted that the app developers were particularly designing apps for children with the combined functioning of other entities who would collect the user data. Also, the FTC argued that the app developers did not inform the advertisers that children were being focused on with their apps. The alarming aspect of these cases was that children were being targeted with specific advertising without allowing parental consent, nor providing notice, for the data that was being collected on their children.
Several app developers who developed apps focusing on children including Hair Salon Makeover, Marley the Talking Dog, My Cake Shop, and Animal Sounds have entered into settlement agreements with the FTC, to the extent that LAI Systems is obliged to pay a civil penalty of $60,000 and Retro Dreamer is obliged to pay a $300,000 civil penalty, both for violating COPPA.