COPPA

[coshea]

Hi

I was going to ask about COPPA compliance, for use with Analytics in games/apps for children, but after signing up and looking at the terms it says:

6. CHILDREN’S APPLICATIONS
6.1 The Service is intended solely for Apps directed to End Users who are 13 years of age or older. If any of your Apps, websites, and online services (collectively, “Properties”) are directed towards End Users under the age of 13, you shall not use the Service for such Properties. By using the Service, you represent and warrant that your Properties are directed to End Users who are age 13 and older.

A shame, because very few analytics company offer this and the kids market is big.

Flurry Analytics have a restricted version for kids game developers, any plans on this front?

Thanks

[markychoi]

Hi Chris. We’re currently doing some more research into this area and scoping out the problem. As of now, we’re in the early stages of better understanding how we might be able to support apps directed at children.

We are investigating how we might be able to support COPPA compliant apps and games. We’ll be sure to update you with any further developments.

[alex_hajdu]

Nice, going to bookmark this thread…

[goat1]

I always found it odd they chose 13 and not 18 years old since this is all about legal responsibility.

I guess they figure 13 year olds have too much financial clout to worry too much about legal responsibility.

[twobob]

We also would like to use this for very simple anonymous metrics in-house for a market including under 13’s.

Watching with interest.

[glacius3000]

According to this thread. Google Product Forums
In particular,

Personal Information

Personal information is information that personally identifies you, such as your name, email address or billing information, or other data which can be reasonably linked to such information. The Google Analytics Terms of Service, which all Analytics customers must adhere to, prohibits the tracking or collection of this information using Google Analytics or associating personal information with web analytics information.

Compared to the COPPA guidelines (page 154):

(a)A first and last name;
(b) A home or other physical address including street name and name of a city or
town;
(c) Online contact information as defined in this section;
(d) A screen or user name where it functions in the same manner as online contact
information, as defined in this section;
(e) A telephone number;
(f) A Social Security number;
(g) A persistent identifier that can be used to recognize a user over time and across
different websites or online services. Such persistent identifier includes, but is
not limited to, a customer number held in a cookie, an Internet Protocol (IP)
address, a processor or device serial number, or unique device identifier;
(h) A photograph, video, or audio file where such file contains a child’s image or
voice;-155-
(i) Geolocation information sufficient to identify street name and name of a city or
town; or
(j) Information concerning the child or the parents of that child that the operator
collects online from the child and combines with an identifier described in this
definition.

It doesn’t seem hard to stay under COPPA compliance as long as you don’t collect any of that information. And lets be honest the only thing we may want to collect in geolocation information but not enough to drill down to a street address.

[sonicviz]

fyi I had an app update knocked back by apple a while back for a kids app, even though I was only using anonymous google analytics. They insisted I needed to implement a popup on app entry to alert the user and get them to accept/reject. Even offering to set the default switch to I had in settings to disallow anon analytics wasn’t good enough.

Funny thing is, 3 other apps with updates with exactly same “issue” went through no problems at all.

From Apple
----- 17.1 -----

We found your app does not obtain user consent before collecting the user’s personal data, as required by theApp Store Review Guidelines.

Specifically, the app automatically sends anonymous usage data without first notifying users.

To collect personal data with your app, you must make it clear to the user that their personal data will be uploaded to your server and you must obtain the user’s consent before the data is uploaded.

iOS 8 includes keys for specifying the reason the app will access the user’s protected data. When the access prompt is displayed, the purpose specified in these keys is displayed in that dialog box. If your application will be transmitting protected user data, the usage string in your access request should clearly inform the user that their data will be uploaded to your server if they consent.

For more information on these keys, please see theInformation Property List Key Reference.

[eezSZI]

Watching this too, it would be great to have an option for a kid-targeted app (exclude certain info by default). General analytics for maintenance and upkeep/improvements are permissible according to COPPA. And as others have said, any Personally Identifiable information is not allowed without parental consent - that is easily avoidable and should mainly be up to the developer.

[eezSZI]

There is now a check box to indicate if your app is targeted for under 13, does this mean it is now allowed?

Coppa Compliance

• In accordance with the Children’s Online Privacy Protection Act (COPPA), we require all products that use Unity Analytics to identify whether or not they are directed at children under the age of 13.
  _This game is directed to children under the age of 13
  _This game is NOT directed to children under the age of 13

I still see the clause in the terms of service saying you cannot target under 13 though:

6. CHILDREN’S APPLICATIONS
The Service is intended solely for Apps directed to End Users who are 13 years of age or older. If any of your Apps, websites, and online services (collectively, “Properties”) are directed towards End Users under the age of 13, you shall not use the Service for such Properties. By using the Service, you represent and warrant that your Properties are directed to End Users who are age 13 and older.

[markychoi]

Hi eezSZI,

As you pointed out, we do now provide you the ability to designate your apps as COPPA compliant. We’ll be coming out with more information about this new feature soon, as well as publish an updated Terms of Service.

[eezSZI]

Thanks for the update! We are eager to try this service, but obviously won’t be able to until the Terms of Service are updated. Please keep us posted!

[sschan]

Hi all,
Please refer to this forum post - Age designation - Unity Services - Unity Discussions for details on how developers may use Unity Analytics for apps directed to children under 13.