New Jersey AG Settles WIth Maker of "Dokobots" App RE Alleged COPPA Violations

http://nj.gov/oag/newsreleases13/pr20131122a.html

Acting Attorney General John J. Hoffman, the Division of Law and the Division of Consumer Affairs announced today that Dokogeo, Inc., a California-based company that makes mobile device applications, has entered into a settlement agreement with the State that resolves allegations it violated the federal Children’s Online Privacy Act (COPPA) and the New Jersey Consumer Fraud Act by collecting personal information about children who used its animation-based “Dokobots” mobile app.

Under terms of the settlement, Dokogeo must clearly and conspicuously disclose – in its apps and on the homepage of its Web sites – the types of personal information it collects, the manner in which it uses such information, and whether it discloses information to third parties. The company also is required to refrain from collecting the personal information of children age 13 and under until it makes the required disclosures, and otherwise complies with COPPA. Dokogeo already has removed all photographs and files containing children’s images from its Dokobots Web site, and has removed geolocation information of children since July 1, 2013.

Dokogeo also agrees to a suspended payout of $25,000. The payout will be due immediately if the company fails to comply with other restraints and conditions included in the settlement agreement. Dokogeo’s $25,000 payout obligation will be vacated after 10 years if it meets all settlement terms, and avoids violating consumer fraud and child online privacy laws.

Almost always , failure to have "clear and conspicuous" disclosure creates problems.