BBB National Programs Archive


New York, NY – March 26, 2012  – The Children’s Advertising Review Unit of the Council of Better Business Bureaus has recommended N49 Interactive modify the website to better protect children’s privacy. The operator has done so.

The site came to the attention of the CARU through its routine monitoring practices. CARU 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 features many different categories that would be of interest to children, including cartoons and TV shows, games, toys, candy and food, music, and sports.  The top of the homepage features rotating banner advertisements, including an advertisement for a game called, “Desert Operations,” and the message, “Commander Wanted!  Click here and play for free.”

As a preliminary matter, CARU’s guidelines make it clear that content that is inappropriate for children should not be advertised directly to them.

In this case, the banner ad featured a game that is intended to simulate the user’s experience as a ruler of a country at war.  The object of the game is to “defend…against hostile takeover,” and “raise your influence in the politics of the world through making alliances or war declarations.”

The Desert Operations website also requires visitors to register by entering an email address.  Once registered, members can freely share information with other members, including personally identifiable information, through the use of the website’s forums.

Based on the mature nature of its content, and the practices involved in participating on the website, it appeared upon CARU’s initial review that Desert Operations was not intended for children under 13.  The Desert Operations website collects an email address for registration purposes and allows players to share personally identifiable information online.

After reviewing the Website, CARU questioned whether the operator linked to other websites that were not in compliance with CARU’s Guidelines.

Upon receipt of CARU’s inquiry, the operator stated that it had removed the advertising elements from the website to provide the safest environment for children.



CARU’s inquiry was conducted under NAD/CARU/NARB Procedures for the Voluntary Self-Regulation of National Advertising.  Details of the initial inquiry, CARU’s decision, and the advertiser’s response will be included in the next NAD/CARU Case Report.


About Advertising Industry Self-Regulation: The National Advertising Review Council (NARC) was formed in 1971. NARC establishes the policies and procedures for the National Advertising Division (NAD) of the Council of Better Business Bureaus, the CBBB’s Children’s Advertising Review Unit (CARU), the National Advertising Review Board (NARB) and the Electronic Retailing Self-Regulation Program (ERSP).


The NARC Board of Directors is composed of representatives of the American Advertising Federation, Inc. (AAF), American Association of Advertising Agencies, Inc., (AAAA), the Association of National Advertisers, Inc. (ANA), Council of Better Business Bureaus, Inc. (CBBB), Direct Marketing Association (DMA), Electronic Retailing Association (ERA) and Interactive Advertising Bureau (IAB).  Its purpose is to foster truth and accuracy in national advertising through voluntary self-regulation.


NAD, CARU and ERSP are the investigative arms of the advertising industry’s voluntary self-regulation program. Their casework results from competitive challenges from other advertisers, and also from self-monitoring traditional and new media. NARB, the appeals body, is a peer group from which ad-hoc panels are selected to adjudicate NAD/CARU cases that are not resolved at the NAD/CARU level. This unique, self-regulatory system is funded entirely by the business community; CARU is financed by the children’s advertising industry, while NAD/NARC/NARB’s primary source of funding is derived from membership fees paid to the CBBB. ERSP’s funding is derived from membership in the Electronic Retailing Association. For more information about advertising industry self-regulation, please visit