FTC COPPA FAQs - I already have a privacy policy for my children’s app. Do I have to change it to comply with the amended COPPA Rule?

Compliance > COPPA
Q:  I already have a privacy policy for my children’s app.  Do I have to change it to comply with the amended COPPA Rule?
 
A:  It depends.  The amended Rule expands the types of information that are considered “personal.” See 16 C.F.R. § 312.2 (definition of personal information).  Therefore, you should examine your information collection practices to determine whether you are collecting information from children that is now considered personal under the Rule, and that now may require you to notify parents and obtain their consent.  In addition, you should review the amended Rule’s requirements for the form and content of privacy notices to make sure that your direct notices (see FAQ C.11 below) and online privacy policies comply (see FAQ C.2 above).  See 16 C.F.R. § 312.4(b) and (d).
 
   
 
 ADDITIONAL INFORMATION:
This information was obtained from the FTC’s webpage on “Complying with COPPA:  Frequently Asked Questions.”   https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions
 

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