Google Play notice that app may be "child-directed" (for the purposes of COPPA)

I got an e-mail from Google Play about one of my apps (which is a novelty app, and is labelled as 3+) - the e-mail is shown below:

Quote:

Subject: Action Requested: Android app child-directed treatment

Dear App Developer,

We’re contacting you because Google has received a report that your Android app(s) and package name(s) listed below may be child-directed for the purposes of the Children’s Online Privacy Protection Act (COPPA). You can visit the Federal Trade Commission’s website to learn more about COPPA.

In 30 days, we will take the action to treat your app(s) listed below as primarily child-directed for applicable Google services that may appear in your app(s). For instance, this means AdMob will take steps to disable interest-based advertising and remarketing ads for your app(s).

If Google should NOT treat your app(s) as primarily child-directed (for example, because it is a mixed audience app), please complete the form(s) below by September 14, 2016.

The question is whether I should use the form they provide to say that this app is NOT “child-directed” or should I allow them to label it as “child-directed” ?

This is what the form says:

Quote:

Certification of app status
You must use this form to certify that your Android app should not be treated as primarily child-directed (note: mixed audience apps are not considered primarily child-directed). No action is required if your app should be treated as purely child-directed.

Please submit 1 form response per app.

Child-directed treatment status *
[ ] Do not treat this app as primarily child-directed.

So basically just because you have your app listed as mixed audience … does not mean that it has to be labelled as “child-directed”.

So I assume that means that having it labelled as “3+” which it currently is now - does not necessarily mean that we should call it “child-directed” ?

As a developer I don’t see what the advantage would be to have the app listed as “child-directed”.

Or perhaps I should change the rating from 3+ to 13+ for the app ? That way, it will not be liable to COPPA ?

Thanks for any clarity on this.

Hi, I have also received such message from Google/

There is no advantage, its more likely there is disadvantage because after you treat your app as “child-directed” AdMob will disable interest-based advertising and remarketing ads for your app(s). But what does it mean “disable interest-based advertising and remarketing ads”? I don’t know.

Also confusing is that the language that Google uses “Google has received a report that your Android app(s) and package name(s) listed below may be child-directed for the purposes of the Children’s Online Privacy Protection Act (COPPA)”.

That does not make clear if this is an “accusation” i.e. some user has said this app looks like a kid’s app, but is showing adult ads (which I have not enabled). Or whether Google is talking about an internal “automated” assessment that this app might be an app that kids may use.

So it does not make clear whether this is a “choice” on part of developer - and it is not clear what this has to do with the “rating” (3+ etc.) that the developer has self-assigned for their app. And what this has to do with the “Designed for Families” program.

Is this e-mail from Google basically related to “Designed for Families” and is basically Google’s way of populating that Designed for Families - but since there are restrictions on app in Designed for Families - that is why Google felt they had to give a 30 day warning to developers so they could opt-out of it.

So this is an opt-in by Google for some apps - and they are just giving the developer an opportunity to opt-out.

Or is this accusatory - i.e. your app is 3+ and it might be showing ads which are inappropriate (although we have disabled those types of ads in Admob). And so either label your app greater than 3+, or stay in, but then make sure you clean up, or let use clean up … ?

However, it seems one can be labelled 3+ rating - and STILL not be in the Designed for Families program.

So it is a bit confusing.

That app is a novelty app and is age-appropriate for all ages.

The only problem could be that the Admob ads being shown are risque. Although I have turned off some categories in Admob Developer Console - Allow/Block Ads tab.

If I allow Google to label it “child-directed” - they will probably adjust the Admob settings automatically to make it child-safe.

Or I could say don’t lable as “child-directed” - and then I go in and try to improve the filtering using Admob - Allow/Block Ads tab.

In this case, the burden will be on me - that the app comply with COPPA - while if I allow Google to do it - then presumably they will do a better job.

The other option is to just change the rating myself from 3+ to 13+ - which would then not trigger COPPA requirements (i not for 13+).

By setting it to 13+ - that means I don’t have to limit the ads etc. ?

And the question then is how is this all related to the “Designed for Families” program ?

Joining that createds a burden on developer to comply - and could be penalized if not.

However if one doesn’t join the “Designed for Families” program - then no filtering of Admob - which may give better fill rate etc.

But you may lose some of the audience from the 3+ crowd.

This link suggests that if you opt into the Designed for Families program - you may get lower fill rate/ad revenue - which is supported by this stackoverflow thread:

admob - Android AdRequest returns only onAdFailedToLoad AdRequest.ERROR_CODE_NO_FILL - Stack Overflow

And Google says that as well:

https://support.google.com/admob/answer/6223431?hl=en&ref_topic=3052726
Using AdMob with the Designed for Families program

Quote:

Ads that are deemed as child- and family-friendly are a subset of the broader ads pool. If you show ads today, after opting-in to the Designed for Families program, you might notice fewer filled impressions and lower revenue. Additionally, apps that participate in the Designed for Families program can’t currently be used to show house ads. This functionality will be available in coming months.

In my opinion/experience, stay away from COPPA, Families, etc

So basically I should say NO to the form and ask to be excluded from this “child-directed” classification.

But then should I change something else - like change the 3+ rating and make it 13+ or something.

If I change it to 13+ - does that reduce the user base ?

And if I don’t change it - leaving the 3+ rating as-is - should I then use Admob Developer Console - Add/Block Ads tab - to remove more possibly borderline categories (I already have much of that removed - but also remove Social/Casino game ads etc.).

Because if I leave it at 3+ - then that still leaves the app open to challenge for not complying with COPPA on it’s own (because it is stating 3+ but the banner ad is showing some risque ad - perhaps a lingerie ad from the Clothings category etc.).

i have the same email too

so, what shoul i do? … if i change the 3+ rating and make it 13+ … everything will be OK ?

I have filled in the form link they gave - to say that “no don’t make the app as child-directed”.

Then I scanned the settings for the Admob Developer Console - Add/Block Ads tabs etc. - and I couldn’t find any objectionable category that was on. So I left that as is.

Now I will wait - if there is some issue, I will change the rating from 3+ to 13+ - but for now I am leaving it at 3+.

I have a couple of similar apps - and those have not gotten an e-mail from Google - so this may have been triggered perhaps by a complaint or something.

Or Google just sends this out to a subset of apps or something.

In any case, the app is still at 3+, and I will consider moving it to 13+ if there is further issue from Google or COPPA or whatever.

It would be interesting to hear other views on what the ramifications of changing 3+ to 13+ would be - obviously it would open up many more ads (so that might be beneficial for the developer) - but will it also reduce the demographics ? I would find it surprising if a phone has itself registered as 3+ for a user - or would it ?

It would seem that not having at 3+ might make the app less likely to be included in the “Designed for Families” program - but then there are complications from lower ad fill rate etc. - so a developer may not want to be included in “Designed for Families” anyway.

So if anyone has further insight into these issues, please comment further.

Thanks.

All my apps has 0+ and 3+ age target, but not all my apps Google mention in letter. I think that google bot scan application description for keywords like “kids, baby, game, children” and then send you letter.

As mentioned here android - Admob child directed settings - Stack Overflow

Ironically, the Children’s Online Privacy Protection Act has nothing to do with content. It is directed toward keeping advertisers from collecting data on a child under 13. As far as the FTC is concerned, adult dating ads are fine as long as you aren’t passing any information about the user back to the advertiser.

In other words, AdMob isn’t broken. It is just fixing a different problem.

So maybe number of impressions will not decrease if we target apps like child oriented.
But it will definitely decrease if we make apps “Design for Families”

To me it feels like google detected some apps may be targeted to children so they will start treating them as child directed (is that sth good?) unless you say no. It doesn´t seem like an accusation. Personally i got 3 apps in the letter, apparently because i used the word “kids” a couple times in their description.

Guys do we have to change anything, I didnt understand whats going on !!!

I recieved the same email from google play and I am surprised, i don’t know how to change the rating of the app if this could be the perfect solution ??

Here is a good Google Play webpage about the Designed for Families program:

https://play.google.com/about/families/

In it one can see, in the monetization section, just how restrictive things are - you cannot use an App Wall (i.e. like what AppBrain would show on exit).

I did as adforandroidapps but I am not sure what will be happened September 14, 2016. Should I move to 13+?

Hey what ended up happening after you guys filled out the form did everything work out ok ??

For me it show a triangle warning mean “There is an problem in this items” right “Pricing & distribution”. I don’t receive any email till today, i just see it when check the app.
My app has name “kids” in the title.

There is and option in Play Console Pricing & distribution : "Primarily Child-Directed Is your app primarily directed towards children under the age of 13 as defined by COPPA ? " with an red text “You are required to indicate if your app is primarily directed towards children.” now it not check “Yes” or “No”. I don’t like to mark the app “YES”.
So there is any problem if i ignore and not check it?

Google Play sometimes rates apps very strangely. I encountered a similar situation a year ago. I still don’t understand why he does it. I decided to completely reinstall Google Play and used a special uninstaller. I tracked all files and records in the app and deleted them, including any residual files. Then I manually installed it again and there was no more problem. I don’t know how effective this method is, but it helped me.


Information about the uninstallers: http://thinkmobiles.com