FTC COPPA FAQs - I have an app directed to children. Do I need to make sure that my privacy policy is included in the app store, at the point of purchase or download?

Compliance > COPPA
Q:  I have an app directed to children.  Do I need to make sure that my privacy policy is included in the app store, at the point of purchase or download?
 
A:  The amended Rule does not mandate that a privacy policy be posted at the point of purchase; rather, the Rule requires that it be posted on the home or landing screen.  However, there is a substantial benefit in providing greater transparency about the data practices and interactive features of child-directed apps at the point of purchase and we encourage it as a best practice.  In fact, the FTC Staff Report, Mobile Apps for Kids:  Disclosures Still Not Making the Grade (Dec. 2012) notes that “information provided prior to download is most useful in parents’ decision-making since, once an app is downloaded, the parent already may have paid for the app...” See p. 7.  Further, if a child-directed app were designed to collect personal information as soon as it is downloaded, it would be necessary to provide the direct notice and obtain verifiable consent at the point of purchase or to insert a landing page where a parent can receive notice and give consent before the download is complete.     
 
 
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
 

Add Feedback