Children’s app  Firefly settles case  with CARU over  violating guidelines and COPPA

Firefly Games agreed to settle with Children’s Advertising Review Unit (CARU) in a case where CARU had found the company had violated Children’s Online Privacy Protection Act (COPPA) by inaccurately explaining its privacy practices. The company agreed to take corrective action to address CARU’s concerns.

During routine review, CARU found the LOL Surprise! Room Makeover app by Firefly that featured dolls and characters intended for children and animated characters, also included content directed to adult users. As the app had a “mixed audience” the app needed to comply with the guidelines of CARU and also COPPA.

CARU found inconsistency between the company’s main privacy policy and the app’s specific privacy policy in terms of their description of cookies, geo-location data, and other items. It was pointed out that the  policies did not reflect the company’s actual practices and violated COPPA. For example, no parental consent was taken for collecting information of children below 13 years before collecting information;  parents were not given information on how the data of children would be used and there was no  age verification process for entry into the app.
Responding to CARU’s allegation, Firefly Games had argued that the app had passed Google’s review process for family advertising however CARU found this unpersuasive, stating “that an app developer cannot rely on a platform’s guidelines or requirements as a substitute for complying with the CARU Ad Guidelines.”