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4. Does the amended Rule prohibit grownups, such as for example moms and dads, grand-parents, instructors, or coaches from uploading photos of children?

4. Does the amended Rule prohibit grownups, such as for example moms and dads, grand-parents, instructors, or coaches from uploading photos of children?

COPPA only covers information collected online from kiddies. It doesn’t cover information gathered from grownups which could pertain to kiddies. Hence, COPPA just isn’t triggered by a grown-up uploading photos of young ones on a general market website or in the non-child directed part of a mixed-audience site.

But, operators of web sites or online solutions which can be mainly directed to kiddies (as defined because of the Rule) must assume that the individual uploading an image is a kid in addition they must design their systems either to: (1) give notice and obtain previous consent that is parental (2) remove any kid images and metadata just before publishing, or (3) produce an unique area for posting by adults, if that could be the intention.

5. My software is directed to kiddies. A kid can upload pictures to the software and manipulate and enhance the pictures in various means, however the software doesn’t send any private information (pictures or elsewhere) from the child’s unit. Have always been we “collecting” personal information due to the fact son or daughter is reaching an image saved from the device?

No. You’re not gathering information that is personal mainly because personal information to your app interacts that is stored in the unit and it is never ever sent.

F. GEOLOCATION DATA

1. We immediately gather geolocation information from users of my children’s software, but i actually do perhaps not utilize this information for such a thing. Have always been I in charge of notifying parents and having their permission to collection that is such

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