FTC COPPA FAQs - I have an app directed to children. At what point in the download process should I send parents my direct notice?

Compliance > COPPA
Q:  I have an app directed to children.  At what point in the download process should I send parents my direct notice?
 
A:  Unless one of the limited exceptions applies (see FAQ H.2), the Rule requires that you send parents the direct notice prior to the collection of any personal information from the child.  The limited exception to this is that you may collect the parent’s online contact information for the sole purpose of sending the parent the direct notice.  Alternatively, you may provide the direct notice to the parent through other means, such as through the device onto which the app is downloaded, if the mechanisms both (1) provide such notice and obtain the parent’s consent before any collection of personal information and (2) are reasonably designed to ensure that it is the parent who receives the notice and provides the consent.
 
 
 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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