16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Some time ago, I became aware of an increase in the number of Internet advertisers and relative business operations that are primarily targeting children by using a suspicious program they refer to as "Neuromarketing Techniques" and another known in their trade as "One-To-One Marketing Strategies," both without having first obtained the consent of their parents! This is alarming, especially finding out that the COPPA RULE - allegedly created to make the Internet safer for children, hasn't been updated in at least TEN YEARS!!! Ten Years???? You've gotta be kidding me! Excuse me, but have any of you even been on the Internet in the last ten years? If you haven't, I strongly suggest that you do so post haste. The Internet today has morphed or changed dramatically from those days of ten years ago when texting was the big deal. Now, children spend oodles of time online which makes them easy prey for the Internet advertisers and their ilk to influence children's behaviors to, for example, buy electronic game$, or maybe "make them" get their parents credit cards and run up huge bills. It's scary that Internet Advertisers and their ilk make use of increasingly complex sophisticated technologies that can swiftly ferret out very personal information that they shouldn't be able to access so easily. With that in mind, the COPPA RULE must immediately be updated with an addendum: "Personally Identifiable Information" about children is an expanding category. In particular, the COPPA RULE should clarify that Operators be required to ask permission of parents, prior to collecting personal information such as: *Children's IP addresses *Children's geolocation information *Children's Screen and User Names *Children's online photographs and videos I strongly urge the FTC to update the COPPA RULE to INSURE that COPPA continues to be an effective tool for protecting children and aiding parents.