A new decision from the Children’s Advertising Review Unit demonstrates the self-regulatory body’s efforts to work with a mobile application and website operator to ensure it complies with CARU’s guidelines and the Children’s Online Privacy Protection Act.

Tiny Piece operates both the 6677g.com website and the mobile application Baby Pet Vet Doctor. The website contained various online games organized by category including favorites, cooking and kids. Users could register for an account by providing an email address, password and date of birth. Once registered, the user could set the account to private or public, which shared the user’s gender, birthdate and email address.

The app was an easy-to-play animated game featuring baby animals. Located in the general games category of the Apple App Store, it was described as a “Kids games” and rated 4+, although it was not located in the Kids category of the store. In the Google Play Store, the app was also located with general games, and although it was rated T for teen, the operator described it as “the perfect game for children.”

“CARU recognizes that there are thousands of apps in the app stores that consist of easy animated games and cute characters that are not specifically targeted to children,” the self-regulatory body wrote. “Here, the subject matter, format and visual content of the App, in combination with the ratings and the descriptions of the App in both app store platforms led CARU to conclude that the App was directed to children.”

CARU had several concerns with both the website and the mobile app. With regard to the website, it lacked a privacy policy and did not collect an email address of a parent when a child registered on the site. Even though the website had actual knowledge that some of its users were under the age of 13 because it collected a date of birth from users, no notice was sent to obtain parental consent in violation of both CARU’s guidelines and COPPA.

As for the mobile app, despite its child-friendly description, it displayed advertisements approximately every 30 seconds, most of which were problematic. For example, CARU observed pop-up ads for other apps created by the operator such as “Plastic Surgery Simulator” and “My Ex-Boyfriend Comes Back,” which featured inappropriate and/or disturbing subject matter.

Other ads promoted 12+ rated games with violent content, such as “Mobile Strike,” described as “an action game of modern war,” or products targeted at adults, like an advertisement for Orajel Cold Sore Relief, an item labeled “Keep out of reach of children.”

“CARU’s guidelines provide that advertisers should take care to assure that only age-appropriate videos, films and interactive software are advertised to children,” the decision noted. Because the app featured “numerous advertisements” for games rated for children 12 and over as well as products that pose a safety risk for children, CARU determined that the in-app ads did not comply with its guidelines.

Tiny Piece agreed to bring both the website and the app into compliance. Specifically, the operator agreed to remove the “Kids” area from its website, block children under the age of 13 from its site, and delete all accounts of users under 13. Turning to the app, the operator agreed to ensure that Baby Pet Vet Doctor will not be recommended for children younger than 12 and will not refer to children in its title or game descriptions in either the Apple or Google store platforms.

To read CARU’s press release, click here.

Why it matters: “As Internet use by young children continues to grow, so does the opportunity for operators and advertisers to interact with and collect data from this impressionable demographic,” CARU wrote in the decision. “CARU’s guidelines recognize the special vulnerabilities of children and were designed to take into account evolving technologies and advertising practice.” The self-regulatory body used the case to emphasize the importance of obtaining parental consent before collecting personally identifiable information from children and limiting in-app ads to age-appropriate products.