Penalty Amount
$3,000,000
The FTC settled with Kuuhuub Inc., operator of the Recolor coloring book app, for violating COPPA by collecting personal information from children under 13 without parental consent. The app's social media features allowed children to register and share data, and third-party ad networks collected persistent identifiers for targeted ads. The settlement requires deletion of children's data, refunds to underage subscribers, a $3 million penalty (suspended upon $100,000 payment), and user notifications about the violations.
The companies must delete all personal information collected from children under 13 unless parental consent is obtained, offer refunds to current paid subscribers who were under 18 at sign-up, pay a $3 million monetary penalty (suspended upon payment of $100,000), and notify app users about the COPPA violations and steps to take.
In-house legal teams should review all agreements involving the Recolor app or similar child-directed services, including vendor contracts with third-party ad networks, customer-facing terms of service and privacy policies, and any data processing agreements. Focus on clauses governing data collection from minors, consent mechanisms (especially verifiable parental consent), third-party data sharing and advertising integrations, data retention and deletion policies, and age-screening procedures. Updates may be needed to ensure robust parental consent workflows, restrict collection of personal information from users under 13, audit and restrict third-party ad network data practices, implement clear children's privacy notices, and establish automatic data deletion protocols for underage users to comply with COPPA.
Entity
Kuuhuub Inc.
Also known as: Kuuhuub
Industry
TechnologyOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2021/07/online-coloring-book-app-recolor-settles-ftc-allegations-it-illegally-collected-kids-personal
1823184recolorcomplaint
https://www.ftc.gov/system/files/documents/cases/1823184recolorcomplaint.pdf
1823184recolorstipulatedorder
https://www.ftc.gov/system/files/documents/cases/1823184recolorstipulatedorder.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Kuuhuub Inc."
"$3 million monetary penalty"
"Children’s Online Privacy Protection Act Rule (COPPA Rule)"
"collecting personal information from children under the age of 13"
"failed to provide notice to parents"
"failed to obtain verifiable parental consent"
The FTC filed a complaint alleging that GovAssist LLC, Entry LLC, and Scott Zuckerman used deceptive paid search ads, misleading service and pricing claims, and fake reviews to deceive consumers seeking passport services. The complaint alleges violations of the FTC Act, the Impersonation Rule, and the Gramm-Leach-Bliley Act; the case will be decided by the court, and no penalty or remedy is reported as imposed.
The FTC issued its annual report to Congress describing fraud trends affecting older adults and the agency’s enforcement, education, and outreach efforts. The report is not a specific privacy enforcement action and announces no penalty or remedy.
The FTC referred a complaint against REPS & Company Inc. and company executives, alleging they bypassed ticket-issuer security controls and purchasing limits to acquire millions of tickets for resale. The complaint was filed by the Department of Justice, and the case will be decided by the court; the press release does not report a penalty or other remedy imposed.
$106.8M
A federal court entered a $106.8 million default judgment against corporate defendants in an alleged debt-relief scheme that impersonated banks and government entities and targeted seniors and veterans. The judgment permanently bans the defendants from the debt-relief industry and imposes additional prohibitions, including on impersonation, telemarketing, and misrepresentations.
The FTC sued Digital Forensics Corporation LLC and affiliated defendants, alleging they misled sextortion victims with promises of investigative and monitoring services that often were not provided, and used fake positive reviews. A federal court granted the FTC’s request to temporarily halt the defendants’ activities; the complaint remains for the court to decide.
The FTC alleged that Greenway Auto Group advertised vehicle prices thousands of dollars below the amounts consumers actually paid and used mailers falsely suggesting recipients had won cash prizes. Greenway agreed to an order requiring transparent pricing and prohibiting deceptive prize mailers and other misrepresentations; the press release does not state a monetary penalty.