Compliant Attribution for Kids Apps
Understanding the legal fundamentals
Privacy and security is top of mind to consumers worldwide. There is a major question mark over what is considered safe, particularly in relation to underage use of technology.
Let’s take a minute to look at the legalities…
Privacy was at the forefront again when Apple announced that iOS would no longer support the collection and use of the IDFA (Identifier for Advertisers) starting with iOS14.5.
Just in case anyone is not in the know…
- COPPA stands for the Children’s Online Privacy Protection Act
- GDPR is the European Union’s General Data Protection Regulation
Addressing the challenges
With this as the framework, developers of children’s apps still need to remain competitive. To do so, they need to be able to analyze the impact of every ad dollar to maximize return on investment (ROI). Without the ability to attribute campaign effectiveness, developers may be reluctant to build dedicated children’s apps as monetization options are limited. Children at the same time deserve and have a right to app experiences that do not jeopardize their privacy rights.
Determining a compliant solution
Singular has a no tolerance policy for privacy work-arounds and goes a step further to ensure that kids app compliance is guaranteed.
Singular built its attribution solution with privacy in mind, ensuring that marketers can access actionable performance insights while maintaining 100% compliance with all regulations and impacting children’s privacy. With the release of iOS 14.5 and the deprecation of the IDFA, Singular continued its promise to privacy-first measurement by building a completely compliant SKAdNetwork Attribution and Analytics solution.
Additionally, Singular developed methods for attribution campaigns without sharing any personal information. The standard solution would send a persistent identifier in a postback to track the user who has installed the app back to the ad they came from. Singular developed a fully customizable postback system that enables advertisers to choose exactly which information to share, if at all.
The solution is compatible with Non-Self Attributing Networks, and it allows advertisers to disable postbacks from Singular altogether or send only non-PI postbacks (“yes/no” using a random ID). Some of these networks (especially gaming-oriented channels) can adequately function without these postbacks from Singular.
Attaining third party approval
Always open to partnership and criticism, Singular shared its solution with PRIVO for assessment to ensure that there was no risk of a child’s data being shared and that the solution met the necessary COPPA and GDPR requirements.
PRIVO is an FTC-approved COPPA Safe Harbor. PRIVO’s Kids Privacy Assured solution also includes GDPRkids™ and Student Digital Privacy Programs.
PRIVO also reviewed the solution for compliance in general, and with its GDPRkids™ Privacy Assured Program, examining the controls to support customers with child-directed apps to ensure they have a lawful basis for processing the identifiers collected.
PRIVO prepared a Privacy Risk and Compliance Assessment and a DPIA (Data Processing Impact Assessment) and determined that the solution posed little or no risk to children when adequately implemented.
Singular has committed to continued oversight for compliance with COPPA and GDPRkids™ and was awarded certification on Oct 15, 2020.
Summarizing the Singular Kids App compliant solution
If you offer a child-directed online service, Singular allows you to:
- Utilize SKAN for iOS apps
Implement our dedicated SDK that does not process or share IDFA or opt-in data. All attributions are based on SKAN only.
- Control all your underage data sharing
Prevent any automatic sharing of device-level data, specifically to any of the major networks (SANs) and own the configuration by which networks receive postbacks.
- Abide by the strictest COPPA and GDPR guidelines with PRIVO assurance
Rest assured that as a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPA Safe Harbor Certification and GDPRkids, Singular is committed to safeguarding children’s personal information collected online.