CARU Strikes Again: Another Mixed Audience App Settles COPPA Allegations – Data Protection

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The Children’s Advertising Review Unit recently found that Tilting Point Media violated COPPA and CARU’s Self-Regulatory Guidelines for Children’s Online Advertising and Privacy. Tilting Point is the operator of the SpongeBob: Krusty Cook-Off app. The case arose as part of CARU’s routine monitoring of children’s content.

CARU has determined that the app is a “mixed audience” app, meaning it is intended for both adults and children under 13. In making this decision, CARU considered a variety of factors, including the fact that SpongeBob attracts children. , as well as the app’s use of music and animation which is also appealing to children.

CARU found that Tilting Point collects personal information from children under the age of 13 and has no mechanism to obtain verifiable parental consent. As a mixed-audience site, however, it was necessary under CARU and COPPA guidelines to obtain verifiable consent. CARU noted that although Tilting Point had an age screen on its app, it was not an effective age-neutral screen. The age screen simply required a user to agree to the app’s terms and privacy policy, which a minor under 13 could easily do.

In addition to consent issues, CARU also found that the app delivered automated advertisements that could not be stopped or dismissed until users downloaded the advertised app or watched the full advertisement. Users were tricked into watching advertisements with the promise of virtual currency rewards. CARU concluded that these ads interfered with play and manipulated children into watching the ads. CARU also found that some of the advertisements displayed were inappropriate and dangerous for children.

In accordance with CARU’s recommendations, Tilting Point Media has agreed to take corrective action, including updating its age screen and privacy policy to align with COPPA and changing its advertising practices, including taking active measures to prevent the display of advertisements dangerous to children.

put into practice: CARU has focused more on sites with mixed audiences. These platforms should keep in mind that under COPPA and the CARU guidelines, they will need an age gate or process to obtain verifiable parental consent before collecting information from kids online.

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