Understanding COPPA Marketing Restrictions

The Children’s Online Privacy Protection Act (COPPA) imposes strict regulations on how businesses can market to children under the age of 13. Organizations must adhere to these regulations to ensure the safety and privacy of young users. Below are three diverse, practical examples of restrictions on marketing to children under COPPA.

Example 1: In-App Advertising Restrictions

Context

Mobile applications aimed at children often include advertising as a revenue model. COPPA mandates that these ads must not be misleading or exploitative.

In this case, a popular children’s game app has implemented strict guidelines on the types of advertisements they allow.

The app developers ensure that all ads displayed within the game are age-appropriate, avoiding any content that may mislead children about the product being advertised. Additionally, these ads must not encourage children to make in-app purchases without parental consent, ensuring full transparency.

Example

• Ad Content Guidelines: All advertisements must be approved by the app’s content team to ensure they are appropriate for children.
• No Direct Marketing: Ads cannot directly encourage children to persuade their parents to purchase items or services.
• Clear Disclosure: Each ad must include a clear statement that it is an advertisement, ensuring children understand they are being marketed to.

Notes

• Some variations may include using pre-approved brands that align with the app’s educational or entertainment value.
• Developers can also provide options for parents to limit ad exposure through settings within the app.

Example 2: Social Media Campaign Limitations

Context

Social media platforms targeting children face strict limitations under COPPA regarding marketing practices. These restrictions aim to prevent children from being targeted with inappropriate content.

A children’s clothing brand wants to leverage social media to market their products but must adhere to COPPA guidelines.

Example

• Age Verification: The brand implements an age verification mechanism to ensure that users under 13 cannot interact with their marketing campaigns.
• Content Restrictions: All posts must be devoid of any promotions that could lead to direct engagement from children, such as contests or giveaways that require personal information.
• Parental Engagement: Any promotional material must encourage parents to engage instead of directly targeting children. For instance, the brand may create posts aimed at parents discussing the benefits of their products rather than appealing to children directly.

Notes

• Brands can still utilize platforms by focusing on educational content that parents can share with their children, thus maintaining compliance with COPPA.
• The use of influencer marketing must also comply with COPPA restrictions, ensuring that influencers do not appeal directly to children.

Example 3: Email Marketing Compliance

Context

Email marketing is another area where COPPA regulations must be strictly followed, especially when targeting children. A toy company wants to create an email marketing campaign for its new line of educational toys.

Example

• Parental Consent: The company must obtain verifiable parental consent before sending any marketing emails that could reach children under 13.
• Content Review: All email content must be reviewed to ensure it does not include any calls to action that could prompt children to click links or make purchases without parental oversight.
• Opt-Out Options: Emails sent must include a clear opt-out option, ensuring that parents can easily unsubscribe from future communications.

Notes

• The company may consider segmenting their email lists to ensure that marketing messages are only sent to parents, thus avoiding direct marketing to children.
• Additionally, emails can highlight the educational benefits of toys, encouraging parents to engage with the content rather than the children directly.