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FTC Settles Kuuhuub Over $3M COPPA Violation

Kuuhuub Inc.July 1, 2021Federal Trade Commission

Penalty Amount

$3,000,000

Summary

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.

Remedy

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.

Monetary PenaltyData DeletionConsumer RefundsCorrective Notice

Contract Impact

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.

Contract Search Terms

verifiable parental consentchildren's data collection clausethird-party data sharing agreementad network SDK integrationage-screening mechanismdata retention policy for minorsCOPPA compliance addendumparental consent formchildren's privacy noticedata deletion upon request

Laws Cited

Violation Types

Entity Details

Entity

Kuuhuub Inc.

Also known as: Kuuhuub

Industry

Technology

Official Sources

Source Evidence

Entity Name
"Kuuhuub Inc."
Fine Amount
"$3 million monetary penalty"
Laws Cited
"Children’s Online Privacy Protection Act Rule (COPPA Rule)"
Violation Types
"collecting personal information from children under the age of 13"
Violation Types
"failed to provide notice to parents"
Violation Types
"failed to obtain verifiable parental consent"

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