How do I contact AgeCheq to ask questions?
You can direct all questions to firstname.lastname@example.org. We are glad to answer any questions you may have.
I make adult audience games. What do I need to do to become COPPA compliant?
If your game only targets users that are over the age of 18, you can simply add an age gate and deny access to your content if the user enters an age that’s under 13. If your game targets a broader audience that includes pre-teens, you’ll need some more help to be fully compliant.
I have a website, can I use AgeCheq to become COPPA compliant?
Yes. Since AgeCheq’s API is a collection of REST HTTP requests, a website has the same access to our services as any other platform. We also have a HTML5 SDK that simplifies integration with our API. Documentation can be found here: http://documentation.agecheq.com/?page=html5#headerSection
How much does AgeCheq cost?
AgeCheq is free to any developer that has under 1 million monthly active users.Once a company has over 1M MAUs, the book price is $1,000 per million MAU. You can contact us at email@example.com if you have any pricing inquiries.
Where do I go to see Documentation and download SDKs?
All of our documentation and SDKs can be found on our documentation site located at: http://documentation.agecheq.com
Will AgeCheq certify that I am COPPA compliant? / Is AgeCheq a safe harbor?
Agecheq is a technology provider, not a safe harbor. We will supply you with all the technology you need to become COPPA compliant and our support staff can help guide you if you have any questions on what is and isn’t legal under the COPPA law. AgeCheq does not certify that apps or websites are COPPA compliant.
What platforms do you support?
Since our API is just a series of REST calls, we support any platform that can execute HTTP requests. For the ease of integration, we have native SDKs for iOS, HTML5, Android, Unity, Corona, Cordova, and Windows Phone 8.
Can I use an age-gate to become COPPA compliant?
Age-gates can help determine which users are under the age of 13. Determining how to interact with these users is directly related to the target audience of your application or service.
General audience: If the user is under the age of 13, you cannot collect any PII from them until you receive verifiable parental consent. You are not allowed to block these users from playing your game or accessing your content.
Child targeted apps: You may not use an age-gate on an app that appeals only to pre-teen children. Your game or app must assume that all users are under the age of 13.
Adult Targeted Apps: You can lock out any user under the age of 13.
What is considered personally identifiable information (PII)?
Here is the list supplied by the FTC on what constitutes PII:
- First and last name;
- A home or other physical address including street name and name of a city or town;
- Online contact information;
- A screen or user name that functions as online contact information;
- A telephone number;
- A social security number;
- A persistent identifier that can be used to recognize a user over time and across different websites or online services;
- A photograph, video, or audio file, where such file contains a child’s image or voice;
- Geolocation information sufficient to identify street name and name of a city or town; or
- Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.
Doesn’t an Apple approved parent gate make my app COPPA compliant?
Many developers believe that Apple wouldn’t allow games that are entered into the Apple* Appstore if they weren’t COPPA compliant. That is not at all the fact. Apple’s definition of a Parent Gate is:
|Parental gates are used in apps targeted towards kids to prevent them from engaging in commerce or following links out of an app to websites, social networks, or other apps without the knowledge of their parent or guardian. A parental gate presents an adult level task which must be completed in order to continue.|
Unfortunately, none of these test have anything to do with whether the app collects any Personally Identifiable Information, which is what COPPA was created to protect. Apple’s Parent Gate’s purpose is to prevent kids from engaging in activity that a parent wouldn’t want without their knowledge.
In fact, Apple’s App Store Guidelines don’t mention COPPA, and only allude to the privacy of a minor in section 17.4:
Please note that Apple won’t necessarily reject an app that doesn’t comply with privacy statues, it only reserves the right to reject the app based on whether the app is compliant or not. That means that if the FTC is going to hand out a fine, the developer and not Apple will be held responsible.
Is Apple’s Vendor ID (IDFV) considered Personally Identifiable Information?
Personally Identifiable Information (PII) is defined as information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. It includes not only specific information about an individual such as their name or address, but also information linked or linkable to an individual, such as medical, educational, financial, and employment information.
Some argue that since there is no connection between a unique identifier and an individual that they are allowed to collect it from a child under 13. The concern is that although some of this information alone seems harmless, when combined with other data they can positively be used to identify someone. For example in 1990 Latanya Sweeney, Chief Technologist of the Federal Trade Commission, proved that 87% of the population of the United States could be uniquely identified by gender, ZIP code, and full date of birth. As a result, a device’s Identity for Vendor (IDFV) as used in a communication exchange is classed as PII regardless of whether it may or may not on its own be able to uniquely identify a person.
This misconception arose because COPPA previously didn’t monitor the collection of these unique identifiers. The Children’s Online Privacy Protection Act changed in July of 2013 to broaden the definition of Personally Identifiable Information.