New York, NY – July 9, 2018  – The Children’s Advertising Review Unit (CARU) has recommended that Starmaker Interactive, administrator of the StarMaker mobile application, modify its privacy practices to bring them into compliance with the Self-Regulatory Program for Children’s Advertising, including CARU’s guidelines on privacy, and the federal Children’s Online Privacy Protection Act (COPPA). The company has agreed to do so.

CARU, an investigative unit of the advertising industry’s system of self-regulation, monitors advertising directed to children in all media and across all platforms. CARU monitors websites and digital platforms for compliance with CARU’s guidelines and with COPPA. CARU is administered by the Council of Better Business Bureaus.

Advertising for the app came to the attention of CARU through CARU’s review of a related product, the Selfie-Mic, marketed by Moose Toys.  The Selfie-Mic, a selfie-stick with a non-removable microphone, plugs into a smart phone and is recommended for children ages 8+.  The Selfie-Mic website recommends using the product with the StarMaker app:

• “StarMaker is the amazing karaoke app which lets you pick top songs from a massive catalogue and sing karaoke like the star you are!

• Please be advised that all app users should be 13 years plus and have parental supervision.”

In the Apple App store, the operator describes the StarMaker app as “a karaoke singing app that lets you pick your favorite songs from a massive catalog and sing karaoke with 40,000,000+ friends all over the world! Edit top quality recordings with a huge range of voice effects and sing and share your covers with all your friends! Music is life, to sing is to live it!”

To register for an StarMaker account, a visitor must provide an email address or cell phone number, or sign-in with a Facebook or Google Plus account.

Once registered, users can share personally identifiable information with the app and other members such as audio and video recordings as well as full name and photos in a personal profile.

When CARU viewed the app it noted that the majority of the videos that appear on the app feature teens and young adults but CARU also observed many accounts that featured children who appeared to be, or identified themselves as, younger than 13 years of age.

The issues for CARU were whether the app was directed to children, either primarily or secondarily, and if so, whether the app’s privacy practices conformed with CARU’s guidelines and COPPA.

Following its review, CARU determined that the app did not primarily target children as its primary audience but several factors indicated that it was directed to children under the criteria set forth under COPPA.
As a mixed audience service, the app is not permitted to totally block children under 13 from engaging with the app.

And here, the app administrator’s obligations are not met by instituting an age-gate. Because the app is directed to children, as outlined by the FTC, the app administrator may age screen, but then must either obtain parental consent or provide child visitors with content consistent with what is being advertised to them in a way that does not involve the collection, use or disclosure of personal information.

StarMaker, in its operator’s statement, said the company accepts CARU’s decision and has “started efforts to incorporate changes to our app, as recommended by CARU.  We appreciate being given the opportunity to improve our App for the purpose of children’s privacy protection and will keep working with CARU to build and maintain a safe and sound online world.”