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Category Archives: Children

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Update on Google Unauthorized Children’s In-App Purchase Class Action: THE SHOW MUST GO ON!

Posted in Children, Class Action Litigation, Privacy Litigation

Written by Julia Siripurapu, CIPP U.S. District Court Judge Ronald M. Whyte has issued an order  granting in part and denying in part Google’s Motion to Dismiss the class action filed against the Company on ­March 7 in the U.S. District Court for the Northern District of California as a result of unauthorized children’s in-app purchases… Continue Reading

COPPA Update: FTC Provides More Flexibility on Obtaining Verifiable Parental Consent

Posted in Children, Privacy Regulation

Written by Julia Siripurapu, CIPP/US Some clarification and a bit more flexibility was forthcoming late last week from the Federal Trade Commission to help ease compliance with the “new” COPPA. In its recent update to three FAQs in Section H (Verifiable Parental Consent) of the COPPA FAQs , the FTC provided important information on the topic of… Continue Reading

Privacy Monday: July 14, 2014

Posted in Children, Federal Trade Commission

FTC Sues Amazon Over In-App Purchases Made by Children  Written by Jake Romero, CIPP Children, according to Whitney Houston, are our future, but they are also, according to the Federal Trade Commission, willing to spend unlimited amounts of money to purchase virtual items within mobile applications.  In a lawsuit filed after Amazon.com, Inc. resisted a… Continue Reading

Round Two for Snapchat: Agreement with the Maryland Attorney General Settling Claims of Consumer Deception and COPPA Violations

Posted in Children, Privacy Regulation

Written by Julia Siripurapu, CIPP Just a little over a month after settling charges of false promises of disappearing user messages (among other things) with the Federal Trade Commission (“FTC”), mobile app developer Snapchat, Inc. (“Snapchat” or “Company”) announced (blog post) that on June 12th  the Company entered into an agreement with the Office of… Continue Reading

FTC Updates COPPA FAQs to Address Education Space

Posted in Children, Privacy Regulation

Written by Julia Siripurapu, CIPP The FTC has just published updates to the COPPA FAQs, the Commission’s compliance guide for businesses and consumers, to address the applicability of COPPA and the Amended COPPA Rule to educational institutions and businesses that provide online services, including mobile apps, to educational institutions. The “COPPA and Schools” FAQs cover in… Continue Reading

Online Protection for Children: Delaware following California?

Posted in Children

Written by Julia Siripurapu, CIPP/US Delaware state representative Darryl Scott recently introduced the Child Online Protection Act (House Bill 261 or the “Bill”), to the state’s House of Representatives. If passed, the Bill would: (1) prohibit the online marketing and advertising of certain products and services to children under the age of 18 (“Minors”) as well… Continue Reading

Unauthorized Children’s In-App Purchases Round Two: Google Faces Class Action

Posted in Children, Class Action Litigation

Written by Julia Siripurapu, CIPP/US Just two months after Apple’s settlement with the FTC over lax parental controls over children’s in-app purchases (see our prior blog post), Google takes the spotlight with claims of unauthorized children’s in-app purchases in the Google Play Store! This time, it’s not an FTC action, but a class action. The… Continue Reading

Complaint from BBB Triggers HarperCollins COPPA-Compliance Measures

Posted in Children, Data Compliance & Security, Online Advertising

Written by Julia Siripurapu The Children’s Advertising Review Unit (CARU) announced (press release) that  it has recommended that HarperCollins Publishers Ltd. (the “Company”) modify its information collection practices on its Ruby Redfort child-directed website (the “Site”) to better protect the privacy of children under 13  (“Children”) and that the  Company has agreed to do so…. Continue Reading

FTC Approves Another COPPA Safe Harbor Program

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu The FTC has announced its unanimous approval for the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule (the “kidSAFE Seal Program”). The Commission’s decision comes after an extended public comment period due to the agency’s shutdown last year.  For more information regarding… Continue Reading

BREAKING NEWS: FTC Announces Major Settlement with Apple

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu and Cynthia Larose Apple Agrees to Pay Consumers At Least $32.5 Million to Settle Complaint of Unfair Billing Related to Children’s In-App Charges FTC Chairwoman Edith Ramirez just announced (press conference) that Apple, Inc. (“Apple”) has agreed to provide consumers full refunds of at least  $32.5 Million Dollars to settle the… Continue Reading

COPPA: New Year, New Requests to FTC For Investigation of Violations

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu As we predicted in our prior blog post reviewing the key children’s privacy developments of the past year, 2014 is turning out to be the year of enforcement of children’s privacy regulations! The first two requests for investigation under the Amended COPPA Rule have been filed with the FTC by the Center… Continue Reading

COPPA: “Knowledge-Based Authentication” Method Approved by Federal Trade Commission

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu The FTC has announced (press release) that it has unanimously approved the knowledge-based authentication method proposed by Imperium, LLC (“Imperium”) as a COPPA-compliant method of obtaining verifiable parental consent (“VPC”). Knowledge-based authentication has been used by entities in the financial services industry to authenticate users for several years. For more information… Continue Reading

On the Seventh Day of Privacy, the FTC Gave to Me….

Posted in Children, Federal Trade Commission, Privacy Regulation

Significant compliance obligations with children’s privacy rules!  Written by Julia Siripurapu, CIPP/US Last December, the FTC gave to us the long awaited (or maybe not so much by covered entities!) final amendments to the 14-year old Children’s Online Privacy Protection Act (COPPA) Rule (the “COPPA Rule,” and as amended, the “Amended COPPA Rule”). Published in… Continue Reading

On the Second Day of Privacy, California Gave to Me……

Posted in Children, Data Breach Notification, Data Compliance & Security, Legislation, Privacy Regulation

Well, the headlines don’t exactly work with the traditional tune, but blame the editor for that….. Written by Jake Romero, CIPP/US 2013 was a busy year for California.  We passed a budget with a surplus, let Kim and Kanye get engaged in one of our stadiums and panicked over possibly losing Sriracha sauce.  At the… Continue Reading

Privacy Monday – November 18, 2013

Posted in Children, Cybersecurity, Privacy Monday, US Supreme Court

The month of November is quickly slipping by – this is the time to be looking at the 2014 cybersecurity and data privacy goals and updates and planning ahead. Our selected bits and bytes for this Monday: FTC Denies AssertID, Inc.’s Application for Obtaining Verifiable Consent Under the COPPA Rule The FTC recently announced (press… Continue Reading

FTC Votes 4-0 to Extend Public Comment Deadline on Two COPPA Proposals

Posted in Children, Federal Trade Commission

The FTC has announced (press release) that, as a result of the recent shut down of the agency, the Commission has voted unanimously to extend the public comment periods for two recent proposals under the COPPA Rule. Specifically, the public comment period for the verifiable parental consent solution proposed by Imperium, LLC (“Imperium VPC Method”) scheduled… Continue Reading

FTC Seeks Public Comment on Proposed kidSAFE COPPA Safe Harbor Program

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu, CIPP In a Federal Register notice to be published shortly, the FTC is seeking public comment on the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule. This provision enables industry groups or other interested entities to submit to the FTC for approval… Continue Reading

FTC Invites You to Comment on Another COPPA Verifiable Parental Consent Method

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu The FTC has announced (press release) that it is seeking public comment on a second verifiable consent method proposed under the Voluntary Commission Approval Process provision of the COPPA Rule. The proponent is Imperium, LLC (“Imperium”), a Connecticut-based technology services company. The Federal Register notice inviting public comment will be published shortly…. Continue Reading

You Can Have a Say on a New Mechanism for Obtaining Verifiable Parental Consent under the COPPA Rule

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu, CIPP Yesterday, the FTC published a Federal Register notice requesting public comment on the first new method for obtaining verifiable parental consent submitted for FTC approval by AssertID, Inc under the Voluntary Commission Approval Process provision of the COPPA Rule. The FTC is particularly interested in receiving comments on the questions… Continue Reading

Amended COPPA Rule Compliance Deadline Approaching

Posted in Children, Data Compliance & Security, Federal Trade Commission, Mobile Privacy, Privacy Regulation

Time flies when it comes to compliance deadlines   As we have blogged here, the Amended COPPA Rule compliance deadline is approaching.   And if you haven’t addressed your compliance issues by Monday, you will be late. Effective July 1, 2013, regulations issued in the December 2012 amendment to the Children’s Online Privacy Protection Act (COPPA)… Continue Reading

The Great Disappearing Acts: California Considers Two Bills Addressing the Removal of Online Information of Minors

Posted in Children, Legislation, Privacy Regulation

Written by Jake Romero Do you ever find yourself worrying that, given the types of things minors deem appropriate to post on social networking Web sites like Facebook and Twitter, our country won’t be able to produce an electable candidate for president in 40 years?  If so, you’ll be glad to know that the California… Continue Reading

July 1 COPPA Compliance Deadline is Approaching

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu Today, the FTC sent more than ninety (90) “educational” letters to domestic and foreign businesses whose Web sites and online services (including mobile apps) appear to collect personal information from children that are 12 years old and under, in an attempt to help the businesses come into compliance with the amendments… Continue Reading

FTC on COPPA: No Delay

Posted in Children, Federal Trade Commission, Privacy Regulation

This afternoon, the Federal Trade Commission (FTC) unanimously rejected requests from industry organizations to delay the July 1 date for compliance with the amendments to the Children’s Online Privacy Protection Act (COPPA).    In its response letter, the Commission noted that the updated rule has been in the works for three years and the July… Continue Reading

War of Words Regarding Implementation of Amendments to COPPA – UPDATE

Posted in Children, Federal Trade Commission, Privacy Regulation

UPDATE — The Federal Trade Commission has published its promised COPPA FAQs here.      Volley #1 – Trade Associations to FTC:  Please Delay! The long-awaited amendments to the Children’s Online Privacy Protection Act (COPPA) have been the subject of much discussion and debate.  Last week, Federal Trade Commission (FTC) Chairwoman Edith Ramirez received letters… Continue Reading