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ARTICLE · 25 JULY 2014

App Developers Should Note Revisions To COPPA FAQs

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The FTC’s July 10, 2014 complaint filed against Amazon has left app developers with concerns about how to make apps that target kids and still comply with the law.

United StatesPrivacy
Foley Hoag LLP
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The FTC's July 10, 2014 complaint filed against Amazon has left app developers with concerns about how to make apps that target kids and still comply with the law. The complaint, brought under Section 5(a) of the FTC Act, alleged that Amazon failed to obtain parents' or account holders' informed consent to in-app charges incurred by children. While the complaint was not brought under the Children's Online Privacy Protection Act (COPPA), the increased scrutiny on child-targeted apps should have all app developers making sure they understand what COPPA requires when it comes to getting parental consent.

Generally, COPPA requires "operators" of online services (including mobile apps) to get "verifiable parental consent" before collecting personal information from a child. This week, the FTC updated its COPPA FAQs page with three new or revised entries elaborating how verifiable parental consent works in the context of mobile apps. Importantly, new FAQ H.10 makes clear

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