Hunton Andrews Kurth writes:
On May 19, 2020, the Federal Trade Commission (“FTC”) announced that it reached an agreement with Swiss digital game developer Miniclip, S.A. (“Miniclip”) to settle allegations that Miniclip misled consumers about its membership in a COPPA safe harbor program.
In 2009, Miniclip joined the FTC-approved Children’s Advertising Review Unit (“CARU”) COPPA safe harbor program and remained a member of the program until 2015, when CARU terminated Miniclip’s participation. According to the FTC’s complaint, Miniclip continued to claim on its website and on its Facebook Games Privacy Policy page that it was a member of the CARU as late as 2019, and therefore, the FTC alleged, Miniclip made false or misleading representations about its participation in the COPPA safe harbor program.
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