With COPPA recently revised, the FTC taking a hard look at children’s apps, and Apple launching a Kids category, Apple has decided to add some serious new children’s privacy provisions to its app developer guidelines. Here are my top 3:
- Privacy notice. Apps will be required to include a privacy notice inside the app. Simply linking to the notice on a website, which is what many children’s apps did to this point, won’t be sufficient. This is significant because it requires a departure from the current strategy of many app publishers of linking to a privacy policy on the Web.
- Restricted links. Apps primarily intended for use by kids under 13 will have to get parental permission or use a parental gate before allowing links out of the app or engaging in commerce. This is significant because the majority of kids’ apps don’t have a parent gate. For an example of a parent gate, see this YouTube video of Warren Buckleitner discussing the Highlights Hidden Pictures Puzzles app.
- No behavioral advertising. Apps for children will be barred from using behavioral advertising, which involves ads that work by tracking what someone does in the app and serving them related ads. This is significant because, as app publishers get smarter about how their audiences are using their apps and how to market inside those apps, they’ll be reminded of what they can’t do with that intelligence.
COPPA: The Children’s Online Privacy Protection Act (though it’s technically the Children’s Online Privacy Protection Rule)
FTC: The Federal Trade Commission, which is responsible for COPPA.
