16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00007 

Submission Number:
00007 
Commenter:
Marty Poulin
Organization:
ShadyLogic, Inc.
State:
California
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503

I have bee na in the Kids online games space for a number of years and have worked for or with Disney, SpinMaster and Activision. Although I can understand some of the proposed actions such as strengthening safe harbors and limiting the use of geo-location data, I strongly urge the committee to reconsider extending the meaning of PII and limiting the use of cookies significantly. Cookies that track a users behavior are critical to the operations and customization of Kids online games! If cookies are eliminated or severely curtailed much of the functionality of Kids games would simply not be possible. While it is possible to customize an experience or gather data in aggregate, this should not be considered PII. It would and should only be considered PII if combined with other PII as already covered in the current definitions. Geo-location data is also valuable in ensuring that a game is compliant with the laws in different regions. A game producer may need to limit the functionality of a game or what features are offered depending on the location of the player. I would be happy to provide mor information on these details if the committee wishes. Marty Poulin CEO, ShadyLogic, Inc.