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"
$930K
The FTC finalized orders requiring CMG Media Corporation (doing business as Cox Media Group), MindSift LLC, and 1010 Digital Works LLC to pay a total of $930,000 for falsely claiming they offered an AI-powered service that could target ads based on conversations captured from consumers' smart devices, and that consumers had opted into such targeting. The orders also prohibit the companies from making misrepresentations about their advertising services, voice data collection, and consumer consent.
The FTC announced it is seeking public comment on a proposed enforcement policy statement regarding personalized pricing, which is the use of personal data to set prices based on what a company believes an individual consumer is willing to spend. The statement warns that undisclosed collection or use of personal data for personalized pricing could violate the FTC Act's prohibition on unfair or deceptive practices. The Commission voted 2-0 to authorize the Federal Register notice.
$4.0M
The FTC and Connecticut secured a $4 million settlement with Chase Nissan LLC (doing business as Manchester City Nissan) over allegations the dealership charged consumers unauthorized fees, including double-charging for 'certified pre-owned' vehicles and inserting charges like total loss protection into financing agreements without consent. The settlement requires $4 million in consumer redress, prohibits misrepresentations about vehicle certification and warranties, mandates prominent disclosure of the maximum total vehicle price, and requires express informed consent for all charges.
The FTC filed a complaint against Credit Glory LLC and related entities for deceptive credit repair practices, including false promises, impersonating debt collectors, charging illegal upfront fees, and using negative option billing without consent. A federal court temporarily halted the operation.
The FTC issued a policy statement abandoning disparate-impact liability, stating it will no longer bring claims based on this theory. It also modified compliance obligations for several companies based on past decisions.
The FTC, along with Utah and California, filed a complaint against Hims & Hers alleging the telehealth provider shared consumers' sensitive health information with third-party advertising platforms without consent, and deceived consumers about billing and cancellation practices. The complaint alleges violations of the FTC Act and the Restore Online Shoppers' Confidence Act.