http://coronalabs.com/blog/2013/05/16/update-on-corona-and-coppa-privacy-policies/(1)
http://business.ftc.gov/documents/alt046-childrens-online-privacy-protection-rule-not-just-kids-sites (2)
I would think it’s accurate to say that we are marketing to a general audience (2), and have covered our own bases (we don’t knowingly collect data on our website, in our app, nor do our third parties from those under 13 and we’ve reflected what does get collected in our privacy policy).
The exception would be our uncertainty about corona’s launchpad analytics.
My thought process after reading much of the material available is that since the only info collected is the following…
- Device type and OS
- An app identifier – this is a string that identifies the Corona app. It does not include any end user info.
- App session time and lengths – this is data on the end user’s usage of the app, but not any personal info.
- IP address – this is the IP address related to the user’s phone connection to the Internet
- Hashed/anonymized MAC address – this is an identifier of the end user’s device
…and none of it can be tied back to an individual child, nor is it telling of their age, I would then think it’d be safe to assume that (using the language from reference 2) we wouldn’t have “actual knowledge” of any person’s age by looking at this data. And thus not in violation of COPPA.
Any more thoughts on the issue, particularly from any staff member savvy in this area, would be awesome.
Thanks!
