CDD files follow-up COPPA complaint on Disney/Marvelkids at FTC/Company needs to do better job on kids privacy and empower parents

Here's a summary from our attorney Eric Null at Institute for Public Representation, Georgetown University Law Center:

CDD filed its initial complaint against Disney and Marvelkids.com in December 2013. Shortly thereafter, Disney updated Marvelkids' nearly two-year-old privacy policy with Disney's company-wide policy. Apparently, Disney thought this would solve its COPPA-related issues, but our investigation shows that it did not. Our review showed multiple deficiencies, including insufficient notice of data collection and use, as well as continued ability to collect and use data for unlawful purposes. Further, its violations include allowing well-known third party behavioral advertisers, such as Omniture and TapJoy, to collect information from Marvelkids.com users--these practices may violate the COPPA Rule. CDD calls on the FTC to take a close look at the new policy and practices, and to investigate Marvelkids.com and all Disney-operated child-directed websites to ensure COPPA compliance.
 
PS: Disney has challenged our complaint, suggesting we are interested in headlines.  What CDD is interested in is meaningful compliance with the key law protecting privacy and empowering parents.  CDD suggests Disney engage in a more serious review of its digital data collection system--something we expect FTC action to help spur. 

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FTC Letter FINAL SUBMITTED.pdf2.79 MB