C. PRIVACY POLICIES AND DIRECT NOTICES TO PARENTS

C. PRIVACY POLICIES AND DIRECT NOTICES TO PARENTS

1. My child-directed web site does not gather any information that is personal. Do we nevertheless need certainly to publish a privacy online?

COPPA is applicable simply to those sites and online solutions that gather, use, or reveal information that is personal young ones. Nevertheless, the FTC advises that every sites and online solutions – especially those directed to children – post privacy policies online so visitors can certainly read about the operator’s information techniques. See mobile phone Apps for youngsters: Disclosures Nevertheless Not Making the level (Dec. 2012) and mobile phone Apps for children: present Privacy Disclosures are Disappointing (Feb. 2012).

2. What information must I use in my online privacy?

Section 312.4(d) associated with amended Rule identifies the details that really must be disclosed in your online privacy policy. Whilst the initial Rule required operators to offer considerable types of information within their online privacy notices, the amended Rule now has a reduced, more streamlined approach to pay for the knowledge collection and employ techniques most important to moms and dads. The online notice must state the following three categories of information under the amended Rule

  • The title, address, phone number, and current email address of all of the operators gathering or keeping private information through the website or solution (or, after detailing all such operators, give you the email address for just one which will manage all inquiries from moms and dads);
  • A description of just exactly what information the operator collects from young ones, including perhaps the operator allows kiddies to help make their private information publicly available, how a operator makes use of such information, additionally 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 use, and state the procedures for doing this. (mais…)

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