The app's non-declinable privacy policy and terms of service provide that the user must be at least 13 years old to use the company's product, but the age gate does not prevent a child under age 13 from checking those boxes and playing the game.ĬARU's Advertising Guidelines make clear that advertisers must not manipulate or deceive children. Tilting Point does have an age screen on its app, however the age screen did not prevent CARU from using the app as a 10-year-old child, agreeing to Tilting Point's terms of service and privacy policy, and consenting to the processing of his/her data for the purpose of receiving 'personalized' advertising. Given the app's child-directed subject matter of SpongeBob Squarepants, intended for ages four and up, its use of animated characters, fun background music, and simplistic nature of the gameplay, as well as information provided by Tilting Point that the app has adult users with a nostalgic connection to SpongeBob Squarepants, CARU determined that the Tilting Point app was a 'mixed audience' child-directed app and as such is subject to COPPA and CARU's Guidelines.Īs the operator of a mixed audience child-directed app, Tilting Point is required under COPPA and CARU's Privacy Guidelines to ensure that either no personal information is collected, used, or disclosed from users under age 13, or that notice is provided and verifiable parental consent is obtained prior to such collection, use, or disclosure.

The SpongeBob: Krusty Cook-Off app, featuring SpongeBob characters licensed by Viacom Media Networks, came to CARU's attention through its routine monitoring of child-directed content.

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