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COPPA applies to personal information collected online by operators of both websites and online services.

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However, the Commission’s 1999 Statement of Basis and Purpose notes that the Commission expects that operators will keep confidential 64 Fed. Although COPPA does not apply to teenagers, the FTC is concerned about teen privacy and does believe that strong, more flexible, protections may be appropriate for this age group. The Rule also covers operators that allow children publicly to post personal information. The Rule does not require operators to ask the age of visitors.

FTC Report: Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers (Mar. The FTC also has issued a number of guidance documents for teens and their parents. Finally, as the FTC made clear in the amended Rule, the passive tracking of children’s personal information through a persistent identifier, and not just its active collection, also is covered by COPPA. However, an operator of a general audience site or service that chooses to screen its users for age in a neutral fashion may rely on the age information its users enter, even if that age information is not accurate.

Marketing Your Mobile App: Get it Right From the Start. The Commission does not consider ‘clear and prominent’ a link that is in small print at the bottom of the home page, or a link that is indistinguishable from a number of other, adjacent links.” mandate that a privacy policy be posted at the point of purchase; rather, the Rule requires that it be posted on the home or landing screen.

These materials can provide you with helpful guidance. The amended Rule states that the “operator must post a prominent and clearly labeled link to an online notice of its information practices with regard to children on the home or landing page or screen of its Web site or online service, at each area of the Web site or online service where personal information is collected from children.” 16 C. However, there is a substantial benefit in providing greater transparency about the data practices and interactive features of child-directed apps at the point of purchase and we encourage it as a best practice. The Rule requires operators to make reasonable efforts, taking into account available technology, to ensure that a parent of a child receives direct notice of the operator’s practices with regard to the collection, use, or disclosure of personal information from children, including notice of any material changes to practices to which the parent previously consented.

COPPA SAFE HARBOR PROGRAMS Congress enacted the Children’s Online Privacy Protection Act (COPPA) in 1998.

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