16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00222 

Submission Number:
00222 
Commenter:
Steve Kohn
State:
New York
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503

Ganz’s Ad Policy claims parents can opt their children out of seeing third-party ads on Webkinz. But in direct contradiction to that claim, Ganz continues to expose children to third-party advertising even after parents opt out. Ganz violates the Children’s Online Privacy Protection Rule (COPPA Rule) both by failing to link to its Children’s Privacy Policy from the Webkinz.com homepage, and because its Children’s Privacy Policy is vague, confusing and contradictory. Ganz’s Children’s Privacy Policy is misleading because it states that the information collected at Webkinz.com cannot be used contact children online, when recent research strongly suggests that the data collected can be used to identify and contact a child. Ganz’s practice of installing cookies on children’s computers to track their activities and serve kids targeted ads without affirmative parental consent constitutes an unfair trade practice.