BBB National Programs Archive

CARU Reviews Website Operated By Matter Group

New York, NY – Feb. 12 , 2009 – The Children’s Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc., has recommended that Matter Group, LLC, modify the Website to assure the site is in compliance with CARU’s self-regulatory guidelines for children’s advertising and the federal Children’s Online Privacy Protection Act (COPPA.) The company has taken steps to do so.

The Website came to the attention of CARU through CARU’s routine monitoring practices.  CARU examines Websites to assure compliance with CARU’s Self-Regulatory Program for Children’s Advertising, including CARU’s guidelines on Online Privacy Protection, as well as with COPPA.

The Website at issue, based on the Xeko collectible card game, is aimed at engaging visitors in fun activities while teaching them about the environment. The Website features “Club Xeko,” which provides children with information about upcoming Xeko events, as well as the Green Star Program which allows children to earn points toward downloads. The site also offers a newsletter that provides updates on Xeko’s mission.

CARU determined upon its initial review that the site allowed children under the age of 13 to circumvent the age-screening process by simply going back and entering an age 13 or above, at which point the child would be allowed to register.

In addition, the registration sections for the Club Xeko feature contained tip-off language to children under 13 years of age by advising that “Kids under the age of 13 have to supply the valid email of a parent or a guardian so we can let them know you’ve asked to join Club Xeko…”

Both CARU’s Guidelines and COPPA require that a Website operator must directly notify the parent of the nature and intended uses of the information collected, and permit access to the information sufficient to allow a parent to remove or correct the information. 

Finally, the site included a hyperlink to a blog area where children could potentially disclose personally identifiable information to third parties. Because hyperlinks can allow a child to move seamlessly from one site to another, CARU requires that operators of Websites for children should not knowingly link to pages that do not comply with CARU’s Guidelines.

In response to CARU’s concerns, the Website operator noted that it was in the process of launching a new Website and changed its registration process to eliminate tip-off language and assure that the age-screening mechanism could not be circumvented. Further, the company has modified the registration process to assure that parental notification would occur in real time, with an email going out to the parent of an under-13 member at the time the child registers. The operator has limited collection of information necessary to sign-up for the company’s newsletter and has removed the hyperlink that CARU identified.

CARU noted in its decision that it is pleased the Website operator has taken steps to better address children’s privacy and to comply with the Guidelines and COPPA.

The company, in its advertiser’s statement, said it “welcomed the opportunity to improve our site recently offered by CARU.”