Gain Market Share with an Unexpected Target Audience

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Kevin Ford

September 22nd, 2015

Gain Market Share with an Unexpected Target Audience

Many apps appropriate for general audiences currently ignore a large and potentially valuable part of their market – children under 13.  Why?

Up until now, many mobile app and game makers have chosen not to attract users under the age of 13 out of fear of fines from the Children’s Online Privacy Protection Act (COPPA), even though those users could legally use their app.

COPPA was created to keep online services from collecting Personally Identifiable Information (PII) from children under 13 without their parents’ consent.  Since COPPA went into effect, the conventional wisdom had been to leave this market alone rather than risk fines from a law that was still new and unfamiliar.  And yet, in ignoring this market today, developers are actually missing a great opportunity to capture a large group of new users who they can safely and legally serve.

Understanding the Scope and Working within the Guidelines

Why has ignoring the kids’ market has become the norm?  One of the biggest reasons some developers exclude kids is the expanded definition of “Personally Identifiable Information.”

Examples of PII covered by COPPA include:

  • Child’s Name, Screen Name, or User Name
  • Facebook or other social networking account information
  • Telephone Number
  • Social Security Number
  • Personal Photographs, Videos, or Audio
  • Geolocation
  • Email Address
  •  Any Persistent Identifiers such as IP address, Advertiser ID, Vendor ID, or cookies

Navigating this rule can seem challenging because of the expanded definitions of PII, but it is worth doing.  If you pay attention to the details and let parents know that you respect the laws about their children’s Personally Identifiable Information, you’ll have the potential to win a large new audience.  Here’s how…

Set Up an Age Gate

The appropriate way for a game or app to manage users under 13 is to set up an age gate.  Users who self-identify as being older than 13 may use your app or game normally and legally.  It is tempting just to ban younger users, but COPPA states that if the game or app has any appeal to children under 13 you must either allow them to participate without collecting any Personally Identifiable Information, or first get Verifiable Parental Consent (VPC) before collecting that information.


Get Verifiable Parental Consent

Verifiable Parental Consent (VPC) is the process of getting a parent’s permission to collect their child’s PII.  There are three parts to VPC.  First, you must prove that the person consenting is in fact an adult.  The rule outlines several methods available to positively identify a parent:

  • Parents may sign a consent form and return it to by mail, fax, or electronic scan.
  • Parents may make a monetary transaction using a credit card.
  • Parents may call trained personnel using a toll-free telephone number or video conference.
  • Parents’ identity may be verified by checking a form of government-issued identification against databases of such information.

Once you verify a parent, you’re required by law to tell the parent exactly what Personally Identifiable Information you will collect in your game or app and get their approval.  Finally, you must provide a way for parents revoke their approval if they no longer want to allow you to collect or retain PII on their kids. This mechanism must signal the game or app to delete all Personally Identifiable Information on the child and cease future collection.

Grow Your Audience for Long Term Value and Loyalty

Adding this unexpected target segment of children under 13 gives your game or app a larger audience, which ultimately means more revenue and potential for long-term value.  If you don’t have the resources to collect VPC, consider integrating a COPPA compliance service like AgeCheq.  Services like AgeCheq allow you to focus on your game or app’s success rather than requiring you to spend development time and resources to work around allowing kids to play without collecting any information about them. AgeCheq’s basic service is free with the option for larger developers who want extra features to upgrade to a paid account with more features.

By expanding your reach to the under 13 market, your game or app will benefit from having more users to draw from, and parents will appreciate your attention to a child’s privacy which will, in turn, add more customer loyalty and revenue.

Kevin Ford

Marketing Manager


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