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santa 120You know Dasher and Dancer and Prancer and Vixen, COPPA and Cupid and Donner and Blitzen…  Whoops! COPPA is not one of Santa's eight tiny reindeer. It's the acronym for the "Children's Online Privacy Protection Act," a law that gives parents more control over who collects information from and about their children. The rules apply to all mobile apps and websites, even those based at the North Pole. The Apple and Google app stores list more than 50 Santa-themed apps this year; children can watch Santa feed live reindeer, track his sleigh on Christmas Eve, or relay their electronic Christmas wish-lists.

COPPA, updated in 2013, was designed to assure that parents have the opportunity to consent to the collection of personal identifiable information (PII) from children under the age of 13. PII can include names and addresses, email addresses, birth dates, photographs, or geolocation information… all of which a crook could use for identity theft.

Better Business Bureau's Children's Advertising Review Unit (CARU) is advising parents on how to use "Santa apps" and related holiday entertainment. Before allowing a child to download any app, CARU recommends that parents:

Read the Privacy Policy. The best holiday apps directed to children provide a description of the service's information collection practices before a parent or child downloads an app to their device.
Understand PII use. Online services directed to children may not collect, maintain or share a photograph, video or voice recordings of a child from children without first getting consent from a parent or guardian. Apps that track Santa's progress on Christmas Eve may be using technology that is precise enough to identify the street, city and state where your child's device is located. This collection would require consent by a parent whereas collecting a general location such as a city or zip code would not.
Set permission requirements. Many apps that are listed as free in the app store have in-app purchases that might be accessed by children after a parent has allowed them to download the app – this is especially easy with the new Touch ID feature on the iPhone 6 (or newer). Ensure your child's device is set to require a password for each download.
Review the app first. Many free apps also include advertising.  If an app is meant for both children and parents to use, then not all of its advertisements may be appropriate for younger children and may contain ads for games or films rated for older audiences.

CARU asks parents who come across an app or other online service that they think violates COPPA to file an anonymous consumer complaint on CARU's website.

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