On May 6, 2019, the Federal Trade Commission announced that Meet24, FastMeet and Meet4U—three dating apps owned by Ukrainian-based company Wildec LLC—were removed from the Apple App Store and Google Play Store following an FTC letter alleging that the apps potentially violated the Children’s Online Privacy Protection Act (“COPPA”) and the Federal Trade Commission Act (“FTC Act”). According to the letter and contrary to what was claimed in their privacy policies, the apps, which collect dates of birth, email addresses, photographs and real-time location date, failed to block users who indicated they were under the age of 13.
In the letter, the FTC requested the app operator to immediately remove personal information collected about children on its services, seek parental consent prior to allowing minors access to the services and ensure that all versions of the apps comply with COPPA and the FTC Act.
Under COPPA, operators of sites and services that have actual knowledge that personal information is being collected from children under the age of 13 must make certain disclosures in their privacy policies and obtain parental consent prior to collecting that personal information. Section 5(n) of the FTC Act prohibits practices that are likely to cause substantial consumer injury if (1) substantial injury is not reasonably avoidable by consumers themselves and (2) those practices are not outweighed by countervailing benefits to consumers or to competition.