From: julie_finlay@pleasantco.com
To: HQ.DCMAIL4(KIDSRULE)
Date: Tue, Apr 27, 1999 5:03 PM
Subject: Comments about Children's Online Privacy Protection Act of 1998

To : C. Lee Peeler
FROM: Julie A. Finlay, Editorial Manager for American Girl Online
http://www.americangirl.com
(owned by Pleasant Company)

RE: Comments about the Children's Online Privacy Protection Act of 1998

DATE: 4/23/99

Thank you for this opportunity to respond to the guidelines being proposed for the Children's Privacy Protection Act. As the manager of a Web site geared to girls 8-12, I am certainly concerned about the protection and safety of my online audience, and about the ramifications of this act. It was very helpful to see the guidelines spelled out.

If you view the American Girl site, you will notice that we solicit quite a bit of input from our visitors. Each week we post a poll question and a help question that girls can respond to with their own advice. We also ask girls to send us their ideas for future poll questions and for submissions to our To Do Today feature---literally a new idea, activity, joke, tongue twister, or game to play every day. These areas of our site are truly the life blood. We post as much as we possibly can from girls. It is a forum upon which they depend. We do not collect e-mail addresses for any of these solicitations. Even if girls send them to us voluntarily, we do not use them in any way--not to respond, nor to store in any database. In addition, when we post a girl's submission we identify her only by first name, age, and state. This measure protects her anonymity yet acknowledges her contribution, thereby encouraging self-esteem. We edit out any information (names of acquaintances, specific places, etc.) that might make a girl identifiable in any specific way. We also encourage girls to use screen names as a measure of safety.

The one area in which we ask a girl to give us her e-mail address is if she wants a response to a question, comment, or suggestion sent to us through our E-mail Us button. Our wording is as follows:

Please include your e-mail address if you would like us to respond to your message.

We will use your e-mail address only to respond to your message. It will not be sold or distributed to any other company, nor will it be used for any mass mailings.

It is Pleasant Company's long-standing policy to respond to each and every letter received from fans or critics of the company. That response is a one-time communication that seems to fall within the parameters of the guideline that fulfill "a specific request of the child." What concerns me is the guideline that reads: "For a one-time contact, the e-mail address collected may be used only to respond to the child. Then, the website must delete it." We keep these correspondences intact and filed for two years for liability reasons. Deleting the e-mail address when we have absolutely no intention to use it for any other reason seems like a maintenance headache. Isn't our word enough when we state that we will not use the e-mail address for any other reason?