FTC COPPA FAQs - When I send a direct notice to parents, may I send them a simple email containing a link to my online privacy policy?

Compliance > COPPA
Q:  When I send a direct notice to parents, may I send them a simple email containing a link to my online privacy policy?
 
A:  No.  As described in FAQ C.11 above, the amended Rule makes clear that the direct notice to parents must contain certain key information within the four corners of the notice itself, depending on the purpose for which the information is being collected.  Therefore, you may not simply link to a separate online notice.  Note, however, that in addition to the key information, the amended Rule requires that each direct notice you send also contain a link to your online privacy policy.  The intention of these changes is to help ensure that the direct notice functions as an effective “just-in-time” message to parents about an operator’s information practices, while also directing parents online to view any additional information contained in the operator’s online notice.
 
 
 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