Yes. COPPA doesn’t need you to allow young ones under age 13 to take part in your overall market internet site or service that is online and you might block kids from participating if you so select. By comparison, may very well not block kids from taking part in an internet site or online solution that is directed to kids as defined because of the Rule. See FAQ D. 2 above.

You should take care to design your age screen in a manner that does not encourage children to falsify their ages to gain access to your website or solution if you opt to block kids under 13 on your own basic market site or solution. Ask age information in a basic way at the point where you ask people to offer private information or to create a person ID.

In designing a basic age-screening apparatus, you should think about:

• ensuring the information access point enables users to enter how old they are accurately. An example of an age-screen that is neutral be a method enabling a person easily to enter thirty days, time, and 12 months of delivery. A website which includes a drop-down menu that only licenses users to enter delivery years making them 13 or older, wouldn’t be considered a basic age-screening apparatus since kids cannot enter their proper many years on that web web site.
• Avoiding encouraging kiddies to falsify what their age is information, for instance, by saying that site site site visitors under 13 cannot participate or should ask their moms and dads before participating. In addition, just including a check package stating, “I am over 12 years old” wouldn’t be considered an age-screening mechanism that is neutral.

In addition, in keeping with long standing Commission advice, FTC staff advises employing a cookie to avoid kiddies from back-buttoning to enter a various age. Remember that in the event that you ask individuals to enter age information, and after that you fail either to display screen out kiddies under age 13 or even to get their parents’ permission to collecting these children’s information that is personal, you are responsible for breaking COPPA. See, e.g., the FTC’s COPPA situations against Path, Inc., Playdom, Inc. And Sony BMG musical Entertainment.

4. We run a basic audience video gaming web site and don’t ask people to reveal their many years. I really do allow users to submit feedback, responses, or concerns by e-mail. Exactly what are my obligations if we get an ask for an e-mail response from a person whom shows that he’s under age 13?

Underneath the Rule’s one-time reaction exclusion (16 C.F.R. § 312.5(c)(3)) you might be permitted to deliver an answer to your youngster, through the child’s online contact information, without giving notice towards the moms and dad or getting parental permission. Nevertheless, you need to delete the child’s online contact information from your own documents immediately when you send your reaction. May very well not utilize the child’s online contact information to re-contact the kid https://media.gettyimages.com/photos/vivelarooney-when-liv-needs-to-learn-french-for-an-upcoming-interview-picture-id512558884?s=594×594″ alt=”adam4adam”> (or even for just about any function), or disclose the child’s online contact information. Remember that you must still immediately delete the child’s personal information from your records if you choose not to respond to the child’s inquiry. Also, such a message can provide you real knowledge if you had previously collected the child’s email address as part of a website registration process) that you have collected personal information from a child (e.g.,. This kind of a scenario, you will have to make a plan to ensure you’re complying with COPPA, such as for instance acquiring consent that is parental instantly deleting any information that is personal gathered through the kid.

5. We operate a broad market online solution and never ask people to expose their many years. But, i actually do allow users to generate their very own weblog pages, and my solution features quantity of online discussion boards.

(a) what the results are if a young child registers back at my service and articles information that is pagersonale.g., for a reviews web web page) but will not expose their age anywhere?

The COPPA Rule is certainly not triggered in this situation. The Rule relates to an operator of a general market site if it offers real knowledge that a specific visitor is a young child. If a young child articles information that is personal on a broad market website or solution but will not expose their age, of course the operator does not have any other information that could lead it to learn that the customer is a young child, then your operator wouldn’t be deemed to own obtained “actual knowledge” beneath the Rule and wouldn’t be at the mercy of the Rule’s demands.

But, also where a kid himself has not yet revealed their age on a website or solution, an operator may acquire real knowledge where it later learns of a child’s age – for instance, through a written report from a concerned moms and dad that has unearthed that her kid is participating on the website. Where an operator understands that a specific visitor is a young child, the operator must either meet COPPA’s notice and parental permission demands or delete the child’s information.

(b) what the results are if a young child articles in a forum and announces her age?

If no body in your organization is conscious of the post, then you can n’t have the prerequisite knowledge that is actual the Rule. Nevertheless, maybe you are thought to have real knowledge where a kid announces her age under particular circumstances, for instance, in the event that you monitor your articles, in case a accountable person in your company sees the post, or if perhaps somebody alerts you to definitely the post (age.g., a concerned moms and dad whom learns that their kid is participating on your own website).