YouTube channel owners: Is your content directed to children?

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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.

 
 
 

Comments

I think its really good for the coppa has taken a step further to protect the kids and like my content is made for kids and anyone out of all ages

FTC, if you really read these, I would appreciate if you can please reply to this. My questions are how is a channel owner meet the definition of a website? A channel owner cannot control who signs up and who doesn't to the platform they are on. Where as if I owned a website I could control that. I could ask parental permission and then proceed to block features on that child's account. So right there COPPA gets thrown out in the court of law. Any judge with common sense would throw that out. A channel owner does not collect anyone's personal information. That's another that would be thrown out. Also how can you label families who like to vlog their life like Yawi Vlogs, Bratayley, KittiesMama, J House Vlogs, 8 Passengers as "Child-Directed"? And then proceed to force them to remove their monetization, remove their comments, playlists, notifications, likes, favorites, end screens, info cards? If losing monetization isn't bad enough, You are tearing down any form of engagement on a channel owners account. How is that fair? It's like forcing Instagram to disable comments, notifications, live videos, etc. on anything child related all because a child may sign up to the platform to follow and comment on a post. You're taking away any form of engagement which isn't fair to anyone.

The blog explains that if a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is:

  1. directed to children, and if
  2. the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads),

the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements.

my question is what will happen to animators such as minecraft and five nights at freddy's animators ?

I made a account 7 years ago and I’ve lost complete access I have no way to retrieve this account I’m afraid of FTC LAW and was wondering what I can do since I can’t access the account to change anything and YT has no way for me recover the account since when it was made there only a one way sign in I don’t want to be fined please help

That settlement is not in compliant with the law. According to your own FAQ about COPPA, it's only applicable when a for-profit company tracks a known child. In the case of children being tracked incidentally, the fact is that YouTube cannot differentiate between child viewers and adult viewers means it's outside the scope of COPPA.

The issue of advertising directed at children is silly, because when I was a child watching TV the ads were most certainly directed at me. To this day, ads on television that feature shows that target children are themselves targeting children and the FTC has not stopped it. Why is YouTube any different? Focus on the tracking, not the content.

Setting all that aside though, that deal between Google and the FTC does not constitute an agreement among content creators. YouTube is free to setup rules, and enforce them by termination content, but fining users for mislabeled content doesn't seem legal because those content creators are still not collecting information about children. Even if they were, unless they have advertising on their channel and are not established as a non profit they are exempt from COPPA so I don't see how any of this is enforceable.

Meanwhile, Google is knowingly collecting personal information from children in the form of voice recordings around smart TVs. It can differentiate between the voice of a child and an adult, but I'm not allowed to uninstall the Google Assistant software. Amazon is doing this as well with Alexa and Apple with its software. Why hold content creators accountable for the type of content in a manner that television is not accountable when there is REAL issues like this being ignored?

The FTC's Six-Step Compliance Plan for Your Business says you must comply with COPPA if:

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

I still don't see how the COPPA rule applies to content creators. Yes, I can see the argument that a channel is treated as if it is operating its own website, but the rule explicitly states that it is only applicable when the information being collected is knowingly about a child. In the example given in this article, that's not clear. That person from Springfield could be a child or it could be an adult. Since the content creator has no way of knowing that the information is not applicable to the rule.

Furthermore, unless the content creator is actually receiving ad Revenue for their Channel they aren't considered for profit and since the rule is only applicable to for-profit companies I really don't see how any of it is enforceable across the board.

Do you mean to tell us that you intend to fine individuals that are not receiving any ad Revenue (not for profit) because a child may or may not be present? (no identifiable child)

What about liability in the case that the YouTube bot decides to use a label incorrectly? If we are not allowed to change the label to something more appropriate, and that label is ruled by the FTC to be in violation, how can we be held accountable for a label created by YouTube?

On the flip side, what happens if a person who isn't even receiving ad Revenue to begin with just labels all of their videos as kid friendly just to avoid the possibility of being sued by the FTC, but this content ends up not being suitable for children? Aren't you harming children?

You can see examples of channels the FTC considered to be directed to children in the complaint in the YouTube case.

For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

we read that, and it doesn't answer the question.

Why must you ruined content creators for making something they love to do? Don't blame the creators. Your just going to ruined people's lives and their jobs. I want to create videos, but now I don't know what's going to happen.

"Youtube kids" exist for kids. Why not "Youtube adults" for adults.

But not all animated content were make for kids!

Sorry if you have anything to say about children.

If I upload a video and seem it not for children, can the FTC go ahead and say they think it is for kids and fine me anyways? I wanted to start uploading content but am scared that I will be fined into debt for making a video even if I dont get much if any money for it

I record my sons (11 years) football games and share them via YouTube channel. Very few people who visit there. Mostly boys who wanna see their game again and family members who were not able to see game live. Occasionally coaches use those recordings to show to the boys what they did well and where to improve. I have no idea should I now tag my channel as children's channel or not.

Isn't YouTube dishing out the personalized ads and not the creators? And you can't really control who sees your content(except when you age restrict it).

The Six-Step Compliance Plan for Your Business says You must comply with COPPA if:

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

What happens if a video meets one of the guidelines? For example, a video geared for teenagers and adults (because of the use of power tools) that shows viewers how to turn a toy into a realistic sculpture? Despite the older audience and the not-kid-friendly tools, would the FTC mark such a video as "child-directed" because of the toy? I'm greatly concerned.

The FTC isn't reading anyone's comments. They're copying and pasting. If you are reading them then reply to the questions in my comment - My questions are how is a channel owner meet the definition of a website? A channel owner cannot control who signs up and who doesn't to the platform they are on. Where as if I owned a website I could control that. I could ask parental permission and then proceed to block features on that child's account. So right there COPPA gets thrown out in the court of law. Any judge with common sense would throw that out. A channel owner does not collect anyone's personal information. That's another that would be thrown out. Also how can you label families who like to vlog their life like Yawi Vlogs, Bratayley, KittiesMama, J House Vlogs, 8 Passengers as "Child-Directed"? And then proceed to force them to remove their monetization, remove their comments, playlists, notifications, likes, favorites, end screens, info cards, stories? If losing monetization isn't bad enough, You are tearing down any form of engagement on a channel owners account. How is that fair? It's like forcing Instagram to disable comments, notifications, live videos, etc. on anything child related all because a child may sign up to the platform to follow and comment on a post. You're taking away any form of engagement and hurting creators and causing them to lose the motivation which isn't fair to anyone.

This is a moderated blog; we review all comments before they are posted, as stated in the Comment Policy.

Some commenters have asked who must comply with COPPA. The Six-Step Compliance Plan for Your Business says you must comply with COPPA if:

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

1. You failed to answer my questions
2. Why don't you give a human response, not a cut and paste (what is easy to find on the website) response? That is still robotic

This is a moderated blog, as stated in the Comment Policy. FTC staff people - not robots - review every comment that is submitted. Many of hundreds of people who submitted comments have asked for more information about channels the FTC considers directed to children, and we're showing them some sources of information.

Anyone else feel like with the vague and copy pasted answers that are given, a bot might actually come off more human in their replies? The sources offered are not very concise, offering little to no actual answers. Meanwhile the ftc openly seem to ignore the fact that as it states in the terms of service for youtube that someone requires to be above the age that coppa covers to be on youtube to begin with, as such the content creators are not liable for anyone under the age seeing their video regardless of the viewers age. Especially considering that the content creators are not even the ones collecting any information.

The FTC's Six-Step Compliance Plan for Your Business explains when you must comply with COPPA. You must comply with COPPA if: 

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

I'm really confused as to what to mark my videos as because I looked at my analytics and it shows everyone that has visited my channel is 13 and older and I do show dolls and toys but I'm an adult collector I feel like I'm not getting enough info and I want to conform to the laws

If content creators have no ability to determine what data (cookies) is or isn't collected on YouTube, why should we be at fault if a child is watching a video made for adults?

Furthermore, by settling the case with YouTube, YouTube has failed us creators who make content that, while may be geared towards adults, could potentially appeal to children.

My argument is, I have collected no data as a channel owner, and thus am not culpable under COPPA regardless of whether a child watches my video or not.

My main audience age is 65+, but because I do art, I could see all ages watching if they desired. Just because a kid might not understand when I talk about my life (my job, chores, life stuff) doesn't mean they're excluded from my rated G channel.

Do you punish movie creators with COPPA if an online streaming app gathers information about a kid while watching the movie?

Instead, let us rate our shows like TV and films, and hold the data collection party responsible for fines if they fail to comply. I have no data. I have not collected anything on any child.

it would be amazing if you would actually clarify WHICH videos are made for kids and which are not. also, i think that taking legal actions vs creators that marked their video wrong is a bit... too much?;; you know, small channels can't really afford a lawyer to consult if their channel is safe or not... i think taking legal action would be okay after informing the creator to change the setting of the video and if they still don't change it,, i don't want to quit my yt channel,

You can see examples of channels the FTC considered to be directed to children in the complaint in the YouTube case.

For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

My friends at FTC, all your intentions are awesome, but PLEASE, I BEG YOU to keep in mind how vague are the rules you are imposing to all YouTubers. We really want to play UNDER THE RULES, but it is very hard to play when we are not sure what are the rules. Thank you so much for reading this. Please help us to get all these mess fixed.

YouTube is for adults u have to be over 13 to join so that said it is the parents fault if they allow them to use it not anyone else's if s parent let's a child watch an 18 rated movie would u chase the movie distributor???? No the parent is to blame for allowing it why are content creators being punished for bad parenting.... there is youtube kids for kids stuff simple as that.... children under 13 should be using that platform to view stuff....
Also why dont YouTube use bank details to confirm your account and I'm not meaning charge people for the service but many other sites use this method in creating an account to determine who you are and your age..... PayPal do this they actually deposit 1p into your account but its secure and would solve the issue of children viewing on a site that they shouldn't be on in the first place....
Also why are creators being targeted when an over 14 site is collecting data the channel creator's arnt collecting data the site is but again if parents diddnt break the rules and allow their children access to a site they shouldn't be on in the first place how can anyone be to blame but the parents ... just my views

so I have a question, I make gacha life videos (basically animation) and most of the videos that i make have suicide, death and murder so if it is animation and the content is like what i said like above shoukd i list it as for children of non children and wil i be under COPPA since it is animation (NOTE: my target audience is viewers that are above 13 years old not kids but the video is horror animation)

It's unbelievable that you share some generic guide lines like "something found interesting from children", punishing who transgresses with a fine of thousands dollars, instead it was declairing that his channel or his videos aren't directed to childs.
It sounds like: you couldn't stay quiet anymore because a new mediatic dictatorship will judge you without telling you how to be "in rule".
Moreover, all the contents on Youtube is potentially reachable by kids: why don't you work at something like a preregistration which forces to declaire the age of the watcher and denies the possibility of watching contents that aren't comformable to his age?
If i declaire that my videos aren't for kids, but kids anyway search me because i speak about games, i'll be fined? It's ridicoulus and sounds like you aren't able to resolve a problem and you decide to destroy the liberty of expression.
More and more and moreover, i hope you are preparing something for the embarassing mediatic system in your country, because you penalize YouTube, but in all the houses in America there's a television.
Thanks for reading and i hope you will return on your steps, studying something more effective and less castrating.

what about youtubers who play kids games, but have mostly adult viewers and rely an the comments section for ideas? and what about the viewers that are under 13?
will children under the age of 13 not be allowed to go onto youtube even with parent permission?
im confused

does the ftc even know how youtube works?
just add a family friendly option so that the video appears on both youtube and youtube kids

Say goodbye to youtube! Say hello to homelessness and poverty! You might as well delete youtube, or maybe even the world wide web. Or just not do this or update the law. or just add a family friendly option and not fine someone for not having control over their content.

I notice one type of question is being ignored over and over and it's the main question that is causing most of the hysteria among content creatures. If FTC would address that it would call a good 70% of the outcry against this action. Many videos are basically intended for over 13, such as crafting how tos, homestead, farming and livestock, family vlogs etc. That's ALL I make and watch. Every YouTuber I follow us considering stopping their videos because child family members, pets, even (gasp) someone playing with a child or a child playing with a pet. IS THAT IT IS THAT NOT UNDER COPPA? I desperately want to assume the federal government has more sense than that but a solid answer would calm the gears of hundreds of creatures who create nothing harmful and do not TARGET children.

im pretty sure this law will start a civil war

this will ruin millions of lives. it could even kill some people (suicide). stop coppa on youtube. youtube will die with it. of course you won't listen, maybe even not accept this comment. and if you reply, you'll just state something we've already read. so if you see this, please do something about coppa, or just don't do it. people hate this, and you know there's something called youtube kids, right? youtube is meant for ages above 13.

no don't do this don't ruin youtube don't ruin lives don't do coppa

The problem due to COPPA is that;
A. The policy itself is vague and uninformative.
B. The people enforcing said policy are not familiar with the type of content being restricted.
C. Children fake their account information all the time.
D. The jobs of many people would be risked in moments notice; Some people will go into a lifetime of debt trying to pay it off.
E. Many youtubers and content creators are based in other countries; To try and shut them down as well is to violate international policies.
The fact of the matter is that the COPPA policy is infringing just about every right given to us, and should be taken down and put with a new policy instead. One that recognizes the four, and many other issues, that have been stated.
I care about the next generation, but to shut down millions, no, HUNDREDS of millions of jobs is simply unorthodox, unjust, and is borderlining oppression. I do not recognize this policy as "just", nor will I ever.

What about vlogging content

Oh hey time to upload a vid oh no its the COPPA here to confuse me in wether my content is for children or not

What about YouTube kids? Your going to destroy many people's lives, Make YouTube go down (Bankrupt) and your going to make so many people lose the ability to get money from this. They have to pay 42,000 dollars PER VIDEO just for not listing thier video correctly? WHAT ABOUT DRIVING DRUNK With a KID in the CAR? They be paying 10,000 for that. I hope your happy for destroying many lives.

But what about people who have stuff that is technically kid-friendly but aren't necessarily aiming it at kids?
For instance, people who just draw art don't usually have non-kid friendly stuff, but they aren't necessarily aiming it specifically to kids, and still want feedback (which they won't be able to receive if COPPA covers it).
And, this is probably a stupid question, but... How will kids even reach the kid-friendly content of it becomes virtually impossible to access (without a link). Won't the kids just lie about their age and only be able to see the non kid-friendly stuff because all the kid-friendly stuff will be almost impossible to access?
I want to protect children too, I just don't think this is an adequate way of discerning what is kid-friendly and what isn't.
And kids like a huge variety of stuff... And people who aren't kids enjoy "kid's" stuff.
I realize this is a complicated issue, but I just hope The way this is done improves.

Shouldn’t there be revisions of coppa’s rules and laws due to the fact that they were made about twenty years ago? After all the internet has vastly changed from what it once was initially created.

am a small youtuber i am a mixed channel do games on my channel i dont have that sort of money if i get sued by you i live in the uk i think this rule is silly made for kids or not parents are to blame here they need to keep an eye on there child on what they watching cause its silly theirs youtube for kids that they can go on they are just lieing about there age us creators are not baby sitters people need money to live to buy food for there family's have a roof over there heads and you will take it way from them the rule is ridiculous is parents and YouTube fault minecraft and fortnite isn't kids content its everyone adults play minecraft and fortnite i also watch YouTube aswell on minecraft i need it to learn how to build survival things i have a learning disability and adhd i do YouTube and also watch it i learn thing from there and it helps me a lot please dont ruin YouTube its a good community to be in some creators put in mixed content thats not made for kids its minecraft isnt for kids its for everyone fortnite isnt for kids its for everyone

yknow, why do you have to either choose the two extremes, if your content could apply to anyone?

I’m wondering about the age of models. This is referring to children in videos but I don’t understand what the definition of a model or child actor is. I follow lots of family homesteaders who may have their children in videos doing chores or helping plant seeds. Are these considered children models? We have thought about starting a channel in the new year but decided against it because what’s the point of risking getting in trouble if one of our kids pops up in video. Our videos wouldn’t be geared towards kids at all mainly focusing on people who want to homestead on small average. But still there is no way my kids wouldn’t pop up here or there in videos. I don’t consider them celebrity or models or actors.

There is a app called "Gacha Life" and people use it as animation/edits called Gacha Tubers. The new rule you created says that Animation is appealed to everyone. Are Gacha Tubers not affected from COPPA?

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