BBB National Programs Archive

Cartoon Doll Emporium Modify Website Following CARU Review

New York, NY – Feb. 12 , 2009 – The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc., has recommended that Cartoon Doll Emporium, LLC, modify the Website to assure the site is in compliance with CARU’s self-regulatory guidelines for children’s advertising and the federal Children’s Online Privacy Protection Act (COPPA.) The company has taken steps to do so.

The Website came to the attention of CARU through CARU’s routine monitoring practices.  CARU examines Websites to assure compliance with CARU’s Self-Regulatory Program for Children’s Advertising, including CARU’s guidelines on Online Privacy Protection, as well as with COPPA.

The Website, geared toward girls aged 6 to 16, features cyber dress-up dolls, games, forums and a social network accessible through paid and free memberships.

CARU determined, upon initial review, that to register for free, users had to submit a username, email address and a date of birth.  If a user entered a date of birth that indicated that she was under the age of 13, a box appeared requesting a parent’s name and email address.  An email was not sent to the parent.

Once registered, a member could send friend requests to other players that included personally identifiable information (PII) such as an email address.  A CARU staff member was able to send a “friend” an internal email with a telephone number.

The Website also featured forums where children could post messages on various topics. To register for the forums, a visitor had to submit an email address.  A message stated, “You must be 13 years of age or older in order to use this forum.  If you are less than 13 years old, your parents must contact Cartoon Doll Emporium using the contact form on the top of the screen and provide permission for you to use the Website along with their email address.”  CARU did not observe a contact form on the top of the screen.

CARU was concerned that the Website collected email addresses and allowed children under the age of 13 to send PII to other members via an internal mail system without obtaining proper prior verifiable parental consent. Further, the site’s privacy policy did not contain contact and certain other information required by COPPA.

Upon receipt of CARU’s inquiry, the Website operator agreed to modify its filtering system to prevent users under the age of 13 from disclosing PII including street addresses and telephone numbers in the profiles, forums and in its internal messaging system.

The operator implemented neutral age screening for its profile and forum registration process, including a session cookie to prevent children from refreshing the page and changing their dates of birth.

The operator also agreed to amend its privacy policy to accurately describe its information collection practices and include full contact information.

“Cartoon Doll Emporium accepts CARU’s decision in its entirety and has already made all of the changes that CARU recommended,” the company noted in its operator’s statement. “Further, CDE will continue to correspond with CARU to make sure that it not only remains in full compliance with COPPA, but exceeds federally-mandated standards for protecting children online.  CDE is very grateful for CARU’s recommendations.”