FTC Dings coloring book app for drawing outside COPPA privacy lines – Privacy


United States: FTC Dings coloring book app to draw outside COPPA privacy lines

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The Federal Trade Commission (FTC) recently announced a settlement with Kuuhuub Inc., the operator of an online coloring book app, as well as its Finnish subsidiaries Kuu Hubb Oy and Recolor Oy, for violation of the Law Protecting Children’s Online Privacy (COPPA). The FTC alleged that the app collects personal information from children who use the app without notifying their parents and without obtaining their consent, as required by COPPA.

Re-color COPPA violations
According to the FTC, the online coloring book app called Recolor provides pictures that users digitally color on their mobile devices. Although marketed as an “adult coloring book”, the app featured categories aimed at children, including a category called “Children” which included animated characters, cartoon animals and other images that appealed to children. .

The FTC has claimed that children under the age of 13 can create an account by providing an optional email address, screen name and description and profile picture, which are made public to other users. By creating an account, these children could use the social media features of the app, including the ability to upload selfies and other images for others to see and could interact with other users online. , including adults. The companies have reportedly received dozens of complaints from parents and other users about the use of these features by children.

The FTC further claimed that the Recolor app allows third-party ad networks to collect personal information from children under the age of 13 in the form of persistent identifiers used to send them targeted advertisements. According to the complaint, the operators of the app did not notify parents or obtain verifiable parental consent before collecting personal information from children and did not ask ad networks to refrain from using the information. children’s personal information for targeted advertising.

Regulators have stepped up their enforcement of COPPA, including $ 170 million settlement with Google in 2019.

Highlights of the Settlement Agreement
Under the settlement, Kuuhuub Inc., Kuu Hubb Oy and Recolor Oy agreed to pay a fine of $ 3 million, which was suspended from payment of $ 100,000 due to their inability to pay the full amount. The companies have also committed to:

  • Delete all personal information collected from children under 13, unless they obtain parental / guardian consent as required by COPPA;
  • Offer a refund to all parents or guardians whose child was under 13 when they registered for the application; and
  • Inform users of the enforcement of alleged violations of COPPA and the actions users can take in response to the regulation.


  • Even if part of an online service is aimed at children, providers must comply with COPPA by sending a notice and obtaining parental / guardian consent before collecting personal information from children under the age of 18. 13 years.
  • Operators of online children’s apps and services should review their data collection policies to ensure they are COPPA compliant and pay particular attention to social media features that allow users to share information. personal information with others.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.



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