Mobile apps for kids

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  • 1.Mobile Apps for Kids: Disclosures Still Not Making the Grade2+2 FTC Staff Report December 2012

2. Mobile Apps for Kids: Disclosures Still Not Making the GradeDecember 2012 | Federal Trade Commission 3. Mobile Apps for Kids: Disclosures Still Not Making the Grade 4. Mobile Apps for Kids: Disclosures Still Not Making the GradeContents Introduction 1Survey Overview and Recommendations 5Survey Results7Privacy Disclosures and Practices of Surveyed Apps 7Privacy Disclosures7Information Collection and Sharing Practices8Disclosures and Practices of Interactive Features of Surveyed Apps16In-App Advertising16In-App Purchases18Links to Social Media19Conclusion21 Appendix I: MethodologyI-1Appendix II: Additional Information about Apps TestedII-1 Appendix III: Separate Statement of Commissioner J. Thomas RoschIII-1 5. Mobile Apps for Kids: Disclosures Still Not Making the Grade 6. Mobile Apps for Kids: Disclosures Still Not Making the GradeFTC Staff Report1Introduction In February 2012, Federal Trade Commission (FTC) staff issued a report on a survey of mobile apps offered for children in Apples App Store and Googles Android Market, the two largest U.S. app stores. The report, Mobile Apps for Kids: Current Privacy Disclosures are Disappointing,2 found that little or no information was available to parents about the privacy practices and interactive features of the mobile apps surveyed prior to download. As a result, the report called on all members of the kids app ecosystem app stores, developers, and third parties that interact with the apps to provide greater transparency about the data practices and interactive features of apps geared to children. The report stated that FTC staff would conduct a follow-up survey in six months to evaluate whether and how industry had addressed the concerns raised.3 FTC staff conducted its follow-up survey during the summer of 2012. Like the first survey, the new survey examined the disclosures that apps provided about their privacy practices and interactive features, such as links to social media. However, the new survey went a step further by testing the apps practices and comparing them to the disclosures made. Specifically, the new survey examined whether the apps included interactive features or shared kids information with third parties without disclosing these facts to parents. The answer: Yes, many apps included interactive features or shared kids information with third parties without disclosing these practices to parents.1.The primary authors of this FTC staff survey and report are Manas Mohapatra and Andrew Hasty of the FTCs Mobile Technology Unit. They received valuable assistance from FTC summer law clerks Amy Greenspan, Kristen Poppenhouse, and Batool Raza, and staff from throughout the Bureau of Consumer Protection. Ryan Sandler of the Bureau of Economics provided valuable assistance reviewing the survey results, and Jessica Skretch of the Division of Consumer and Business Education created the graphics, charts, and design of the report.2.The first report, hereafter referred to as Mobile Apps for Kids Report, is available at recommendations in this report and the prior report are designed to encourage best practices by companies in the kids app ecosystem. Staff did not examine whether the practices observed violated the laws enforced by the Commission, and some of staffs recommendations may go beyond what would be required to comply with the law.1 7. Mobile Apps for Kids: Disclosures Still Not Making the Grade Since issuing the first kids app report, the Commission has continued to promote consumer protections in mobile technologies by engaging in a host of policy, enforcement, and educational initiatives.4 Additionally, other government agencies, including the California Attorney General and the U.S. Department of Commerce, have launched efforts to increase transparency in the mobile marketplace,5 and several trade associations have issued selfregulatory guidelines or launched initiatives regarding mobile app privacy and related issues.6 Likewise, Apple and Google recently announced changes to their app stores that may address4.In March 2012, the Commission issued a final Privacy Report, which set forth best practices for businesses to protect consumers privacy and give them greater control over the collection and use of their personal data, including when using mobile devices. FTC Report, Protecting Consumer Privacy in an Era of Rapid Change (March 26, 2012) (Privacy Report), available at os/2012/03/120326privacyreport.pdf. Commissioner Rosch dissented from the issuance of the Final Privacy Report. See id. at Appendix C. Further, in May 2012, the Commission held a workshop to bring together representatives from industry, academia, and consumer organizations to discuss how businesses can make effective disclosures in new media, including on mobile devices. FTC Workshop, In Short: Advertising & Privacy Disclosures in a Digital World (May 30, 2012), available at inshort/index.shtml. FTC staff also published guidelines to assist mobile app developers observe and comply with truth-in-advertising and privacy principles. See FTC, Marketing Your Mobile App: Get It Right From the Start (August 2012), available at In addition, the Commission has proposed modifications to the Commissions Childrens Online Privacy Protection Rule, in part to clarify the consumer protections that should apply when children use mobile devices. Press Release, FTC, FTC Seeks Comments on Additional Proposed Revisions to Childrens Online Privacy Protection Rule (Aug. 1, 2012), available at February 2012, the California Attorney General announced an agreement with the six leading mobile app platforms that was designed to ensure that mobile apps available through those platforms post privacy policies for consumers to view. Press Release, State of California Department of Justice, Attorney General Kamala D. Harris Secures Global Agreement to Strengthen Privacy Protections for Users of Mobile Applications (Feb. 22, 2012), available at In June 2012, the U.S. Department of Commerce announced that it was convening a privacy multi-stakeholder process to address mobile app transparency, with the goal to have stakeholders develop voluntary, enforceable codes of conduct. Press Release, National Telecommunications & Information Administration, Department of Commerce, First Privacy Multistakeholder Meeting: July 12, 2012 (June 15, 2012), available at, e.g., Press Release, GSMA, GSMA Announces New Initiative Addressing Mobile App Privacy (Feb. 27, 2012), available at; Press Release, ACT, ACT Introduces the App Privacy Icons (Oct. 4, 2012), available at; CTIA, Best Practices and Guidelines for Location Based Services, available at; Application Developers Alliance, Privacy Summit Series, available at 8. Mobile Apps for Kids: Disclosures Still Not Making the Gradeconcerns about the failure to post privacy policies and the transmission of personal information by apps.7 These efforts have the potential to improve the information available to parents about the apps their kids use. Since the first kids app report was issued, the market for mobile apps has continued to grow at an explosive rate, providing many benefits and conveniences to consumers. As of September 2012, there were over 700,000 apps available in Apples App Store, a 40% increase since December 2011, and over 700,000 apps available in Google Play,8 an 80% increase since the beginning of 2012.9 The rise in the number of apps corresponds to the increasing number of U.S. adults who own devices capable of using apps. According to the Pew Research Center, nearly nine out of ten U.S. adults have a cell phone and more than 40% of these cell phone owners download apps to their phones.10 As consumers embrace of the mobile marketplace has increased, so have their concerns about what mobile apps do with their personal information. For example, a recent Pew study found that 54% of app users decided not to install an app once they discovered how much7.In August 2012, Google updated its developer program policy to state that apps that disclose personal information without authorization are not allowed. Ingrid Lunden, Google Tightens up App Policy, Gets Stricter on Naming/Icon, Payments, Privacy, Ads and Spam Rules [Developer Letter] (Aug. 1, 2012), available at In September 2012, Apple released the newest version of its iOS operating system. The new version allows developers to insert a link to a privacy policy directly on the app promotion page. See Adding New Apps, iTunes Connect Developer Guide, available at Guide/8_AddingNewApps/AddingNewApps.html#//apple_ref/doc/uid/TP40011225-CH13-SW1.8.In March 2012, the Android Market became a component of Google Play. See Jamie Rosenberg, Introducing Google Play: All your entertainment, anywhere you go, Google Official Blog (Mar. 6, 2012), available at Don Reisinger, Can Apples App Store maintain its lead over Google