The Children’s Advertising Review Unit recently settled with KidGeni – a generative art platform intended for children- for allegedly violating both CARU’s guidelines and COPPA. According to CARU, which is a self-regulatory...more
8/19/2024
/ Artificial Intelligence ,
CARU ,
Class Action ,
COPPA ,
Data Collection ,
Enforcement ,
Federal Trade Commission (FTC) ,
Machine Learning ,
Online Platforms ,
Parental Consent ,
Personal Information ,
Privacy Laws
We’ve cautioned before about the danger of thinking only about US state “comprehensive” laws when looking to legal privacy and data security obligations in the United States. We’ve also mentioned that the US has a patchwork...more
The California governor recently signed into law the California Age-Appropriate Design Code Act, which will go into effect July 1, 2024. The law applies to “businesses” (as defined by CCPA) that provide online services or...more
Firefly Games agreed to take corrective action in response to the Children’s Advertising Review Unit’s allegations that the company had violated COPPA by inaccurately (and confusingly) explaining its privacy practices. The...more
The FTC recently took two well-publicized steps in the children’s privacy space. First, it penalized WW International (formerly, Weight Watchers) and its subsidiary, Kurbo, for alleged COPPA violations. Second, it unanimously...more
5/31/2022
/ COPPA ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Mobile Apps ,
Online Safety for Children ,
Parental Consent ,
Personally Identifiable Information ,
Websites
The Children’s Advertising Review Unit recently settled with TickTalk Tech, LLC over its information collection practices. CARU, a self-regulatory body that reaches voluntary settlements with companies, conducts regular...more
4/15/2022
/ Advertising ,
CARU ,
Children's Online Games ,
COPPA ,
Data Collection ,
Data Privacy ,
Disclosure ,
Mobile Apps ,
Parental Consent ,
Personal Information ,
Privacy Policy
OpenX Technologies recently agreed to pay $2 million to settle FTC allegations that the advertising platform violated the FTC Act and the Children’s Online Privacy Protection Act. OpenX runs a programmatic ad exchange,...more
Just as we thought 2022 was going to be significantly different than 2021, December 2021 and January 2022 events have thrown us for another (pandemic) loop. We anticipate that some of the privacy and cybersecurity...more
1/12/2022
/ Artificial Intelligence ,
Auto-Dialed Calls ,
Biometric Information ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
CAN-SPAM Act ,
CARU ,
CDPA ,
Consumer Privacy Rights ,
COPPA ,
Cross-Border Transactions ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Employee Tracking ,
EU ,
FCC ,
Federal Trade Commission (FTC) ,
Food and Drug Administration (FDA) ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Identity Theft ,
Machine Learning ,
Mobile Privacy ,
Ransomware ,
SCOTUS ,
TCPA
As discussed in our sister blog, CARU’s revised Ad Guidelines go into effect on January 1, 2022. While the core principles of the guidelines have not changed, they now include new content to account for today’s advertising...more
8/27/2021
/ Advertising ,
CARU ,
COPPA ,
Federal Trade Commission (FTC) ,
Mobile Apps ,
Online Gaming ,
Online Safety for Children ,
Parental Consent ,
Personally Identifiable Information ,
Privacy Policy ,
Social Media ,
Terms of Service
The Children’s Advertising Review Unit (CARU) recently revised its children’s advertising guidelines to address the increased prevalence of online media directed to children. Of note, the guidelines now apply to content...more
The FTC recently announced the removal of Aristotle International, Inc. from the list of seven approved safe harbor programs under the Children’s Online Privacy Protection Act. Programs that are approved by the FTC must place...more
The new acting FTC chair, Rebecca Kelly Slaughter, recently signaled that the FTC may increase enforcement and penalties in the privacy and data security realm. Slaughter pointed to several areas of focus for the FTC this...more
Throughout 2020 we saw many enforcement actions brought by EU and U.S. regulators. Whether for allegations of deception (misleading privacy representations) or unfairness (failure to protect information), COVID did not appear...more
12/28/2020
/ Biometric Information Privacy Act ,
CAN-SPAM Act ,
COPPA ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Enforcement Actions ,
FERPA ,
GLBA Privacy ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Online Safety for Children ,
TCPA
In our online world, one of the challenges (and opportunities) for companies is the increased use of their websites, apps, and connected devices. For platforms directed to both adults and children, or platforms previously...more
As we wrote previously, kids are spending more of their days online and are using online platforms for virtual learning and entertainment. Much of this environment is funded through online advertising. All companies thus need...more
In the current pandemic era, kids are spending more time online, be it for school or entertainment. Companies are therefore gearing up for increased interaction with children online or through connected devices. As children...more
In this remote era, companies are increasingly being approached by their business teams with ideas about products and services that involve video or audio recordings of their consumers. It may also involve letting people...more
HyperBeard, the makers of several children’s mobile apps (including KleptoCats), recently settled with the FTC over failure to obtain verifiable parental consent before collecting children’s personal information online, in...more
The Federal Trade Commission is requesting comments and input on the effectiveness of the 2013 amendments it made to the Children’s Online Privacy Protection Rule. Although the FTC typically reviews its rules every ten years,...more
7/29/2019
/ Amended Rules ,
Comment Period ,
Cookies ,
COPPA ,
Data Collection ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Online Safety for Children ,
Parental Consent ,
Personal Information ,
Public Comment
As we enter into the second quarter of the year, the FTC has released its annual report on privacy and data security, and the steps it took in those areas over the course of 2018. The report includes summaries of its actions...more