In a recent decision, CARU found Snap Inc.’s (Snap) Snapchat app to be compliant with both the CARU Guidelines and the Children's Online Privacy Protection Act (COPPA).  “The company goes beyond minimal procedures to prevent under-age use” CARU stated. CARU determined that Snapchat is an app directed to a general audience, not intended for use by children. In reaching this conclusion, CARU considered that Snap’s Terms of Service clearly prohibit users under 13 years of age and makes no effort to market the app to children or provide them with an appealing user experience.  With that understanding, Snapchat is permitted under the Guidelines and Children’s Online Privacy Protection Act (“COPPA”) to age-gate and block children under 13 from using its services, which it does. CARU then examined whether Snapchat does so effectively. CARU observed that Snapchat utilizes age-gates and many safeguards to ensure that if children manage to breach the existing age-...

As you might know, in February of this year, TikTok paid an astounding $5.7 million in fines after CARU referred a case against the app to the Federal Trade Commission (FTC). TikTok (aka Musical.ly) is a platform that allows users to create and post short videos lip-syncing to music, in addition to social networking aspects. Now, concerns have arisen about how children’s data is collected  in the United Kingdom. Information Commissioner, Elizabeth Denham, told a parliamentary committee, “We’re looking at the messaging system, which is completely open, we’re looking at the kind of videos that are collected and shared by children online. We do have an active investigation into TikTok right now, so watch this space.” Under the EU’s general data protection regulation (GDPR), a company can be fined up to 20 million euros, or 4% of revenue, whichever is higher for violations. In response, TikTok released a statement saying, “We cooperate with organizations su...