FTC COPPA FAQs - Is it okay for the link to my privacy policy to be located at the bottom of the home page of my website?

Compliance > COPPA
Q:  Is it okay for the link to my privacy policy to be located at the bottom of the home page of my website?
 
A:  The amended Rule states that the “operator must post a prominent and clearly labeled link to an online notice of its information practices with regard to children on the home or landing page or screen of its Web site or online service, and, at each area of the Web site or online service where personal information is collected from children.”  16 C.F.R. § 312.4(d).  In the 1999 Statement of Basis and Purpose, the Commission explained that “‘clear and prominent’ means that the link must stand out and be noticeable to the site’s visitors through use, for example, of a larger font size in a different color on a contrasting background.  The Commission does not consider ‘clear and prominent’ a link that is in small print at the bottom of the home page, or a link that is indistinguishable from a number of other, adjacent links.”  See 64 Fed. Reg. 59888, 59894.  A link that is at the bottom of the page may be acceptable if the manner in which it is presented makes it clear and prominent.  
 
   
 
 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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