5.1.4 Kids

Overview

5.1.4 Kids

(a) For many reasons, it is critical to use care when dealing with personal data from kids, and we encourage you to carefully review all the requirements for complying with laws like the Children’s Online Privacy Protection Act (“COPPA”), the European Union’s General Data Protection Regulation (“GDPR”), and any other applicable regulations or laws.

Apps may ask for birthdate and parental contact information only for the purpose of complying with these statutes, but must include some useful functionality or entertainment value regardless of a person’s age.

Apps intended primarily for kids should not include third-party analytics or third-party advertising. This provides a safer experience for kids.

(b) In limited cases, third-party analytics and third-party advertising may be permitted provided that the services adhere to the same terms set forth in Guideline 1.3.

Moreover, apps in the Kids Category or those that collect, transmit, or have the capability to share personal information (e.g. name, address, email, location, photos, videos, drawings, the ability to chat, other personal data, or persistent identifiers used in combination with any of the above) from a minor must include a privacy policy and must comply with all applicable children’s privacy statutes. For the sake of clarity, the parental gate requirement for the Kid’s Category is generally not the same as securing parental consent to collect personal data under these privacy statutes.

As a reminder, Guideline 2.3.8 requires that use of terms like “For Kids” and “For Children” in app metadata is reserved for the Kids Category. Apps not in the Kids Category cannot include any terms in app name, subtitle, icon, screenshots or description that imply the main audience for the app is children.