BBB National Programs Archive
CARU Recommends Stabenfeldt Modify Advertising, Privacy Practices; Company Agrees To Do So
New York, NY – August 4, 2009 – The Children’s Advertising Review Unit of the Council of Better Business Bureaus has recommended that Stabenfeldt, the owner of PONY, a book club for children, modify its advertising to better disclose that consumers pay shipping and handling when they sign up for a $1 special offer and modify its Website www.Pony4kids.com to better protect children’s privacy. The company has agreed to do so.
CARU, the Children’s Advertising Industry’s Self-Regulatory forum, examined the Website pursuant to CARU’s monitoring program. An advertisement for PONY, “The #1 Book club for Horse-Loving Kids,” appeared in the April 2009 issue of National Geographic Kids. The ad directed children to www.JoinPony.com, which then directed users to www.Pony4kids.com.
The magazine advertisement stated “Special Offer for Girls who Love Horses & Ponies…Join the #1 Horse Book Club and get this Giant Welcome Package for just $1. Plus shipping and handling.” The $1 copy is written in a large, bold font. “Plus shipping and handling” is written in smaller type next to the $1 copy. The first page also describes the contents of the Welcome Package, which includes books, a magazine, a CD-Rom, a collectible figure, a poster, a bookmark, stationary, and a watch.
CARU noted that the print advertisement was two pages long and emphasized that children could join the Club and get the Welcome Package for only one dollar. By contrast, the disclosure, which stated that shipping and handling was not included, was in fine black print and was much smaller than the price. Further, this disclosure did not indicate the actual cost of shipping and handling, which CARU noted was $4.95, nearly five times the cost to join the Club.
The Website, targeted at young horse enthusiasts, allows users to play games, read blogs, send free e-cards, and join the Club. There is also an e-store, which features young girls wearing horse-themed attire and holding horse books, which are available for purchase. Users also have the opportunity to contribute drawings to an online art gallery.. The homepage also includes two links that direct children to www.joinpony.com where children may sign up for the Club. One link is on the top of the page and reads “Become a PONY Member,” the other is a link within the page, which states “Join PONY and get your Giant Welcome Package.”
The Website featured free e-cards that visitors could send to their friends. Upon CARU’s initial review, visitors were asked to enter their full name and email address, along with the recipient’s full name and email address. The e-card, when delivered, would include the sender’s full name and email address. The sender was also able to freely enter personal information into the body of the e-card.
CARU was concerned, as well, that visitors could circumvent the Website’s age-screening mechanism by click a box next to the statement that they are over 18.
Upon receipt of CARU’s inquiry, the company said that it would modify its disclosures in future advertising and implement new privacy practices to ensure compliance with the CARU’s guidelines and COPPA. The company disabled the e-card feature and is installing a neutral age-screening mechanism. CARU noted in its decision that is pleased that the advertiser agreed to make all necessary modifications.
The company, in its advertiser’s statement, said it accepts CARU’s decision in its entirety.