Penalty Amount
$500,000
California Attorney General Rob Bonta and Los Angeles City Attorney Hydee Feldstein Soto announced a $500,000 settlement with Tilting Point Media LLC over allegations that the company violated COPPA and the CCPA by illegally collecting and sharing children’s personal data without parental consent via its 'SpongeBob: Krusty Cook-Off' mobile game. The settlement requires Tilting Point to pay $500,000 in civil penalties and comply with injunctive terms including implementing neutral age screens, obtaining parental consent for children’s data collection/sharing, and maintaining an SDK governance framework. Tilting Point must also submit annual compliance reports to the California DOJ and LA City Attorney’s Office.
Tilting Point must pay $500,000 in civil penalties. Injunctive terms require the company to: comply with CCPA and COPPA for all child-directed games; obtain parental consent for selling/sharing data of children under 13 and opt-in consent for 13-16 year olds; provide just-in-time notices for children's data sales/sharing; use neutral age screens; properly configure third-party SDKs; implement an SDK governance framework; follow advertising laws for minors; and implement a compliance monitoring program with annual reporting to the California DOJ and LA City Attorney’s Office.
In-house legal teams should review vendor agreements with third-party SDK providers to include mandatory configuration requirements, SDK governance audits, and compliance with children’s privacy laws like COPPA and CCPA. Privacy policies and user agreements for child-directed games must be updated to mandate neutral age screens, just-in-time notices for data collection/sharing, parental consent mechanisms for users under 13, and opt-in consent for users aged 13-16. Additionally, operational agreements should include clauses requiring data minimization for minors, annual compliance reporting to regulators, and internal monitoring programs to ensure adherence to children’s data protection rules.
Entity
Tilting Point Media LLC
Industry
GamingOfficial Press Release
https://oag.ca.gov/news/press-releases/attorney-general-bonta-la-city-attorney-feldstein-soto-announce-500000
Complaint People v Tilting Point Media LLC (filed)
https://oag.ca.gov/system/files/attachments/press-docs/Complaint%20People%20v%20Tilting%20Point%20Media%20LLC%20%28filed%29.pdf
Tilting Point Final Judgment (7 2 24)
https://oag.ca.gov/system/files/attachments/press-docs/Tilting%20Point%20Final%20Judgment%20%287-2-24%29.pdf
California Attorney General Enforcement Page
https://oag.ca.gov/privacy/privacy-enforcement-actions
"Tilting Point Media LLC"
"$500,000 in civil penalties"
"California Consumer Privacy Act (CCPA)"
"Children’s Online Privacy Protection Act (COPPA)"
"collecting and sharing children’s data without parental consent"
"Tilting Point’s age screen did not ask age in a neutral manner"
$500K
Tilting Point Media LLC illegally collected and shared children's personal data in its mobile app game 'SpongeBob: Krusty Cook-Off' without parental consent, violating COPPA and CCPA. The settlement imposes a $500,000 civil penalty and injunctive terms to ensure compliance with children's data privacy laws.
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