Children’s Advertising Review Unit Determines that Visual Supply Company App Is Not “Directed Primarily or Secondarily to Children”
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New York, NY – January 21, 2021 – The Children’s Advertising Review Unit (CARU), a division of BBB National Programs, determined that Visual Supply Company (VSCO) is not an online service directed primarily or secondarily to children under age 13 as defined by the Children’s Online Privacy Protection Act (COPPA) and CARU’s own Guidelines for Online Privacy Protection.
Identified during CARU’s routine monitoring program of child-directed content, VSCO markets a social media and photo editor app that has become well known to teens and tweens for the “VSCO girl” trend across several social media platforms.
Concerned about the potential for an online audience of children under age 13, CARU carefully considered whether the VSCO online service would be considered “child-directed” under COPPA and CARU’s Guidelines.
CARU assessed evidence provided by VSCO demonstrating its intent to direct its online service to adults and its safety-by-design approach to development.
CARU’s findings included:
- VSCO is not responsible for and did not encourage use of the “VSCO girl” meme
- VSCO’s use of language and characteristics primarily focused on the benefits of a paid subscription
- VSCO’s tailoring of app functionality and related promotions to an audience of serious photo and video enthusiasts
- VSCO’s choice to not include follower counts or public likes in the app that tend to be popular with younger audiences
CARU also found that VSCO’s app, which is rated 12+ in the Apple app store and “teen” in the Google Play store, is not marketed actively to children under the age of 13.
CARU also looked at the proactive measures put in place by VSCO, including, among other tactics, a Trust & Safety Team dedicated to actively monitoring and responding to reports of underage users in a timely manner and a reporting mechanism within the app so users can report underage or inappropriate content in real time.
As part of its determination, CARU also noted that VSCO chose to implement an age-screen as a best practice to prevent children under age 13 from creating accounts on the service.
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 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.
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