C. PRIVACY POLICIES AND DIRECT NOTICES TO PARENTS
1. My child-directed internet site does not gather any private information. Do we nevertheless have to upload a privacy online?
COPPA is applicable only to those sites and online solutions that accumulate, use, or disclose information that is personal kids. But, the FTC recommends that most web sites and online solutions – particularly those directed to children – post privacy policies online so visitors can certainly read about the operator’s information techniques. See Cellphone Apps for youngsters: Disclosures Nevertheless Not Making the level (Dec. 2012) and Mobile Apps for youngsters: present Privacy Disclosures are Disappointing (Feb. 2012).
2. Just exactly What information should I use in my online privacy?
Section 312.4(d) regarding the amended Rule identifies the info that needs to be disclosed in your privacy that is online policy. Although the initial Rule needed operators to produce substantial types of information inside their online privacy notices, the amended Rule now requires a reduced, more streamlined approach to pay for the information and knowledge collection and make use of methods most important to moms and dads. Beneath the amended Rule, the internet notice must state the next three types of information:
- The title, target, phone number, and current email address of most operators gathering or keeping information that is personal your website or solution (or, after detailing all such operators, give you the contact information for just one which will manage all inquiries from moms and dads);
- A description of just exactly what information the operator collects from kids, including perhaps the operator allows kids to help make their information that is personal publicly available, the way the operator makes use of such information, while the operator’s disclosure techniques for such information; and
- That the moms and dad can review or have deleted the child’s private information and will not permit its further collection or usage, and state the procedures for performing this.