A Legal Guide to PRIVACY AND DATA SECURITY 2024

Interactive Advertising Bureau Mobile Marketing Association

Children’s Online Privacy Protection Act (COPPA) The federal government has focused a great deal of attention on websites (that collect personal information) directed at children under the age of 13. The Children’s Online Privacy Protection Act (COPPA) (15 U.S.C. §§ 6501-6506) requires operators of websites directed at children under the age of 13 (or websites that knowingly collect information from children under 13) to provide a detailed privacy notice regarding their collection and use of children’s data online. COPPA also requires that the operator of the website obtain “verifiable parental consent” before collecting or using children’s information beyond a one-time inquiry. The operator must provide parents with the ability to review the information collected from the child and ask for it to be deleted at any time. FTC amendments to COPPA in 2013 expanded the definition of “personal information” to include persistent identifiers, such as IP addresses and mobile device IDs, which recognize users over time and across different online services. As a result, behavioral advertising on child–directed online services now requires parental notice and consent. COPPA now also applies to geolocation information. According to COPPA, personal information is defined as individually identifiable information about a child that is collected online, such as: • A full name; • A home address; • Online contact information; • A telephone number; • A social security number;

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