The Children's Advertising Review Unit recently found that Tilting Point Media violated COPPA and CARU's Self-Regulatory Guidelines for Advertising and for Children's Online Privacy. Tilting Point is the operator of the SpongeBob: Krusty Cook-Off app. The case arose as part of CARU's routine monitoring of child directed content.
CARU determined that the app was a "mixed audience" app, meaning that it was directed to both adults and children under 13. In making this determination, CARU took into account a variety of factors, including the fact that Spongebob Squarepants is appealing to children, as well as the app's use of music and animation that is also appealing to children.
In addition to the consent problems, CARU also found that the app served automated ads that could not be stopped or dismissed until users downloaded the advertised app or watched the entire ad. Users were induced to watch ads with the promise of virtual currency rewards. CARU concluded that these ads interfered with gameplay and manipulated children to watch the ads. CARU also found that some of the ads that were displayed were inappropriate and unsafe for children.
Putting it into Practice: CARU has increased its focus on mixed audience sites. These platforms should keep in mind that under both COPPA and the CARU Guidelines, they will need an age gate or a process for obtaining verifiable parental consent before collecting information from children online.
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