BBB National Programs Archive

CARU Recommends American Beverage Company Modify Child-Directed Website To Better Protect Children’s Privacy

New York, NY – Oct. 13,  2010 – The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc., has recommended that American Beverage Company, owner of the Website www.littlehug.com, take steps to better protect the privacy of children who visit the site. The operator has agreed to do so. 

CARU, the children’s advertising industry’s self-regulatory forum, monitors Websites for compliance with CARU’s Self-Regulatory Program for Children’s Advertising, including guidelines on Online Privacy Protection, as well as with the federal Children’s Online Privacy Protection Act (COPPA).

The Website came to the attention of the CARU through CARU’s routine monitoring practices. An advertisement for the site appeared in Discovery Girls Magazine, a publication for girls ages 8-12. 

The site offers product information about Little Hug Fruit Drinks, marketed by the advertiser, as well as games and activities.

CARU determined, upon its initial review of the site, that child visitors could elect to “send a hug e-card,” or participate in “Crazy Talk,” a feature that allows visitors to create a story from pre-written sentences and then share the story with friends.

The electronic card option allowed a child visitor to include his or her full name, e-mail address, a friend’s full name and e-mail address and to write a message that could include additional personally identifiable information (PII). The sender’s full name and e-mail address were visible upon receipt of the card.  The “Crazy Talk” feature allowed a child visitor to share the same PII and, again, the sender’s full name and contact e-mail were visible to the recipient of the card.

CARU determined that the features were not in compliance with the Guidelines and COPPA, which require that Website operators must obtain verifiable parental consent prior to disclosing PII of children under 13 to others.

CARU recommended that the operator prohibit the sender’s e-mail from appearing in the recipient’s inbox when sending an e-card, and that the operator disable the free-type function; and that the Operator prohibit the sender’s e-mail from appearing in the recipient’s inbox when sending a “Crazy Talk” message. The operator agreed to do so.

In its operator’s statement, CCM – which operates the Little Hug website on behalf of American Beverage Corporation – said it accepts CARU’s decision in its entirety and has modified the Little Hug Website to remove the operations which did not properly protect the privacy of children.”