16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503 #561789-00095 

Submission Number:
561789-00095 
Commenter:
Cedric Sellin
Organization:
YogiPlay
State:
California
Initiative Name:
16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503

My name is Cedric Sellin and I am the co-founder of Yogi Play. My wife and I are long time technologists – she is one of the early employees at Google and I was a member of the founding team at Aruba Wireless Networks. We see the power technology can have in everyday lives and now, as parents, see the power mobile devices have to be both fun and educational tools for our children. We founded Yogiplay to give parents insight into their kids' learning and development within a network of curated, high quality learning apps. Our team includes educational experts as well as highly skilled developers and a marketing team with experience from top brands. All of the apps on our platform are vetted by a team of educational experts to help parents find age-appropriate apps for their children. We understand the devices are not going away so it's best to take advantage of the positive aspects of these tools. We are working within the currently written COPPA laws as we grow our business. Our goal is to provide a parent corner within third party applications to move all the parent features behind a protected area rather than being child facing. It could solve a lot of the privacy issues for smaller third party developers. We could use the progress of the children in the various applications to provide the best recommendations to parents. I am also concerned about the "reason to know" standard mentioned in the proposed rule. If a large platform provider, like Apple, has “reason to know “that the apps are directed at children, even if they do not collect any information, the platform may decide to not allow these apps in their marketplace to avoid possible great liability that is not under their control. If the app developer does get verifiable parental consent for each user under the age of 13, the app stores could still make a blanket policy to reject all children's apps – The liability risk is too high. The unintended consequences of this standard are far reaching, could put many kids app developers out of business, and devoid them of a great learning tool which advances them 21st century technology. The last thing I'd like to mention is that a screen name should not be considered personal information. These screen names, when they do not include a child's full name or an address, are valuable to the user when logging in and maintaining autonomy. It's a way to create a personalized experience without collecting personal information. Thank you for your time and I look forward to the final rule.