Verizon is changing its privacy policy to allow for the collection and processing of geolocation information. The usual lawsuits have been filed. I’m curious about all those kids using cell phones. COPPA applies if you are targeting children under the age of 13 and collecting PII from them or know that children under the age of 13 are using your service and you are collecing PII from them. I think I see a compliance snafu! Little Suzie needs a privacy officer.
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Doesn’t COPPA only apply to websites and “online services?”
The new FTC regulations directly implicate this scenario:
“For example, the FTC proposes to modify the definition of “personal information” subject to COPPA to include persistent identifiers such as an Internet Protocol address, cookies, a processor or device serial number, unique device IDs, and any “identifier that links the activities of a child across different websites or online services.” These would be considered stand-alone categories of personal information, even though not linked to other identifying or contact information such as a name or email address, unless used solely for the maintenance of website or online service technical functionality.”
http://www.martindale.com/internet-law/article_Lerman-Senter-PLLC_1368238.htm
“While neither the COPPA statute nor the Rule defines a ‘‘Web site located on the Internet,’’ the term is broadly understood to cover content that users can access through a browser on an ordinary computer or mobile device.38 Likewise, the term ‘‘online service’’ broadly covers any service available over the Internet, or that connects to the Internet or a wide-area network.39 The Commission agrees with commenters that a host of current technologies that access the Internet or a wide area network are ‘‘online services’’ currently covered by COPPA and the Rule. This includes mobile applications that allow children to play network-connected games, engage in social networking activities, purchase goods or services online, receive behaviorally targeted advertisements, or interact with other content or services.40 Likewise, Internet- enabled gaming platforms, voice-over- Internet protocol services, and Internet- enabled location based services, also are online services covered by COPPA and the Rule.”
Click to access 110915coppa.pdf