BBB National Programs Archive

CARU Recommends CDE Modify Website to Better Protect Children’s Privacy; Company Agrees to Do So

New York, NY – Aug. 6, 2014 – The Children’s Advertising Review Unit has recommended that modify its website to better protect children’s privacy. The company has agreed to do so.

CARU is an investigative unit of the advertising industry’s system of self-regulation. It is administered by the Council of Better Business Bureaus.

CARU monitors advertising to children in all media. CARU also examines websites and apps for compliance with CARU’s Self-Regulatory Program for Children’s Advertising – which includes guidelines on online privacy protection – as well as with the federal Children’s Online Privacy Protection Act (COPPA).

The website, administered by Cartoon Doll Emporium, Inc., came to the attention of CARU through CARU’s routine monitoring of the Internet.

The site is described as a safe, carefully moderated gaming website and social network where children can play games, make friends, upload photos, enter contests, invite friends, create avatars, and purchase and acquire virtual goods.

Upon review, CARU found that the site:

  •  Employed an age-screening process that allowed visitors to go back the original registration screen and change their ages, circumventing certain privacy protections
  •  Did not include a link to its privacy policy or inform the parent or guardian that personally identifiable information (PII), including full names and street addresses, could be shared by children in its direct notice to parents or guardian
  •  Allowed children to disclose PII without first obtaining parental consent
  •  Allowed children to upload photos of themselves and attach captions that included PII without first obtaining parental consent 
  •  Contained advertisements for products that were rated for mature audiences.
  •  Did not obtain parental consent before allowing third parties to collect information that was then used to recognize users over time and across different websites for advertising purposes

Following its review of the site, CARU recommended that the operator modify its privacy practices to bring the site into compliance with CARU’s guidelines and the federal Children’s Online Privacy Protection Act (COPPA), which the company agreed to do.
The company, in its advertiser’s statement, said that is has “reviewed the case decision and … accepts CARU’s decision in its entirety and has already made all of the changes recommended by CARU. We will continue to correspond with CARU to make sure that our site remains in full compliance with COPPA and its advertising regulations and practices. CDE is very grateful for CARU’s recommendations.”