Two of BBB National Programs’ Self-Regulatory Watchdogs Bring Azerion Gaming Website and App into Compliance with Privacy Best Practices

McLean, VA – March 9, 2021 – Two self-regulatory watchdog units of BBB National Programs, the Digital Advertising Accountability Program (DAAP) and the Children’s Advertising Review Unit (CARU), today released the result of a new data privacy case for the children’s gaming site Girls Go Games and the mobile app My Dolphin Show.  

Azerion, the publisher of Girls Go Games and My Dolphin Show, worked with DAAP and CARU to bring its online services into compliance with the Digital Advertising Alliance (DAA) Principles for privacy and interest-based advertising, and CARU’s Advertising Guidelines, respectively.  

DAAP and CARU monitor the mobile app marketplace and the web, conducting network traffic tests of popular mobile apps and websites and opening formal inquiries where they find a gap in compliance with privacy best practices.  

During that monitoring, DAAP and CARU discovered third parties collecting mobile device identifiers through My Dolphin Show, a mobile game that has more than fifty million downloads in the Google Play Store. DAAP and CARU also discovered that the Girls Go Games website, owned by the same company, contained third-party trackers collecting data for interest-based advertising. 

Both the app and the website failed to obtain parental consent or screen users under the age of 13 for the third-party collection of that data. 

DAAP and CARU opened a formal review and sent the company an inquiry letter addressing these issues. In response, Azerion, which had acquired the Girls Go Games and My Dolphin Show properties during the pendency of the joint review, worked quickly to meet the DAA and CARU interest-based advertising data privacy requirements.  

The company fully addressed DAAP and CARU’s concerns by:  

• Removing advertising entirely from the My Dolphin Show app 
• Removing all third-party data collection for interest-based advertising from the Girls Go Games website, and disabling all data-sharing and remarketing with their advertising partners
• Engaging an outside auditor to review their practices and ensure compliance
• Updating its internal guidelines and practices
• Taking steps to ensure that only advertising that is appropriate for a child audience will be displayed  

”On behalf of both teams here at BBB National Programs, I want to thank Azerion for adopting all of our recommendations, which required major revisions to the app and website at issue,” said Jon Brescia, Vice President, Digital Advertising Accountability Program, BBB National Programs. “As this case shows, self-regulation can get real results.” 

DAAP and CARU have conducted other joint operations in the past, including a joint referral to the Federal Trade Commission in 2019. 

All BBB National Programs case decisions can be found in the case decision library.

### 

About BBB National Programs:  BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org. 

About the Digital Advertising Accountability Program: The Digital Advertising Accountability Program (DAAP), a division of BBB National Programs, was developed by the Digital Advertising Alliance (DAA) to enforce industry self-regulation principles for data privacy in online and mobile advertising, holding companies accountable to the DAA’s Privacy Principles. DAAP provides guidance to companies looking to comply with industry principles and responds to complaints filed by consumers about online privacy.  

About Children’s Advertising Review Unit: The Children’s Advertising Review Unit (CARU), a division of BBB National Programs and the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children from deceptive or inappropriate advertising and ensure that, in an online environment, children's data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action.