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Apple's App Store and Google Play list dozen of holiday-themed apps: children can video chat live with Santa himself, light the menorah, watch Santa feed live reindeer, track his sleigh on Christmas Eve, or relay their Christmas wish-lists. With COVID-19 continuing to affect kids' access to in-person activities like visits with Santa, apps may continue to play a large role in the holiday season. Before allowing a child to download any app, be sure what data it's collecting and set permission requirements.
BBB National Programs’ Cameryn Gonnella, Compliance Manager for the Children’s Advertising Review Unit (CARU) recommended these tips to keep in mind this holiday season.
Know your Privacy Rights
The Children’s Online Privacy Protection Act (COPPA) gives parents control over who collects information from and about their children. COPPA applies to all mobile apps and websites directed to kids, even those based at the North Pole. COPPA, updated in 2013, was designed to ensure that parents can consent to the collection of personal information from children under the age of 13. Personal information includes names and addresses, email addresses, birth dates, photographs, or geolocation information.
Tips for Parents
Before downloading any app, parents should:
- Look for a privacy policy and give it a skim:
Responsible apps directed to children provide a description of the
service’s information collection practices before a parent or child
downloads an app to their device. COPPA requires, at the very least,
that the privacy policy be on the homepage of the app when you open it.
Many apps also have a link in the app store platforms. If you can’t find
a privacy policy, that’s a red flag. It’s very likely that they’re on
Santa’s naughty list. A privacy policy should include: A list of who is
collecting personal information; what information the device collects
and how it’s used; how personal information is stored; who has access to
data; a list of your parental rights, and consumer opt-out tools
- Learn what personal information is collected:
Online services directed to children may not collect, maintain or share a
photograph, video or voice recordings or even a device identifier of a
child from children without first getting consent from a parent or
guardian. The law also requires that apps get parental consent before
allowing kids to disclose personal information publicly. Before your
child downloads an app, check out what information it might collect
using helpful tools like Apple's new Privacy Details section in the App Store.
- Set permission requirements: Many apps that are
listed as free in the app store have in-app purchases that might be
accessed by children after a parent has allowed them to download the
app. Ensure that your child’s device is set to require a password for
each download.
- Be wary of free apps: Most free apps contain more
advertising than apps that require even a nominal fee. Free apps, even
those labeled as educational, may have deceptive and disruptive
advertising practices—some even advertise inappropriate content. Ads may
pop up extremely frequently and kids are often required to view these
ads in full to continue in the game. Ads may also trick kids into
clicking by placing them behind enticing items like coins or adorable
creatures. If an app is meant for both children and parents to use, then
not all of its advertisements may be appropriate for younger children;
it may contain ads for games or films intended for older audiences.
Finally, even a free app that does not display advertising might have
third-party code collecting data for later future ad targeting. To
avoid surreptitious ad targeting, make sure to adjust your iOS or Android device settings.
- Think before you download: Sometimes, free apps
might contain a form of malicious code called malware. To avoid
downloading an app that might cause problems with your phone, make sure
it’s page in the app store has a privacy policy link, contact
information, and address information for the app publisher. Use common
sense when looking at the app to see if it appears reputable. Crude
designs or imitations of commonly known cartoon or fictional characters
might be a red flag.
- Check out reviews: Services such as Common Sense Media tell whether the app’s content is appropriate for your child.
CARU asks parents who come across an app or other online service
that they think violates COPPA to file an anonymous consumer complaint
on CARU's website.
For more information about CARU and keeping children safe online, please visit the BBB National Programs’ website.