In this article, SUR IT MARZIPAN UNLOOSEN CUTS LTD (“we” or “Marzipan”) explain how we work with mobile apps that indicate to us that they are child-directed apps subject to the US Children’s Online Privacy Protection Act (“COPPA”), and/or to other applicable data protection laws, such as the EU General Data Protection Regulation (“GDPR”) and/or to Google Play’s “Designed For Families” program, that restrict processing of information collected from children.
When a publisher adds a new app to the Marzipan platform, or at any time while using the Marzipan platform, the Publisher must inform Marzipan if the app is directed to children, as required by applicable law, as explained in this article.

As a Publisher, you are responsible for:

• Evaluating your apps, and determining if your apps are child-directed
• Correctly flagging your apps as child-directed on your Marzipan dashboard, and setting the COPPA SDK Functionality, as further explained below
• Ensuring that your apps comply with applicable laws

To further understand your obligations under the COPPA, we recommend that you read the materials here: https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy
Publishers must choose for each of their apps the correct flag that applies to their apps, as further explained below.

How to flag apps as not directed to children?

If your app is not directed to children, as defined by the COPPA, you should choose the “not directed to children” flag in the dashboard (as seen in the screenshot below). In this case, you can still use the COPPA SDK Functionality to flag specific devices for compliance with applicable laws, such as the GDPR, or the UK’s Age Appropriate Design Code.

If the app is primarily directed to children (as defined by the COPPA), the publisher should flag the app in its dashboard as follows. This flag will apply to all end-users of the app.

How to flag an app as child-directed?

If the app is primarily directed to children (as defined by the COPPA), the publisher should flag the app in its dashboard with the “Primarily Directed to Children” flag. This flag will apply to all end-users of the app.

How to flag a specific end-user as a child?

If the app is partially, but not primarily, directed to children under the COPPA (sometimes called a mixed-audience app), and has implemented an age gate, then the publisher should flag the app as a “Mixed Audience” app in its dashboard. In this case, the publisher must use COPPA SDK Functionality to flag whether a specific end-user is a child below the age of 13 (or another age as applicable to the publisher and app), or not.

Publishers are responsible for determining whether an app is primarily directed to children or the app is permitted to use an age gate.

Prohibition on Ads to, and Personal Information from, Children and Apps Exclusively Designed for, or Exclusively Directed to, Children

Publisher must comply with all applicable laws and policies governing the collection and use of personal information from children in any jurisdictions where you have end users. This includes the Children’s Online Privacy Protection Act (“COPPA”), laws of similar effect in any applicable jurisdiction in the collection and use of “Personal Information” (as defined by COPPA or other applicable laws) from children, and any applicable app store policies.

Marzipan does not knowingly collect personal information from children or serve ads to children under 18 years of age

Publisher may not provide Marzipan with personal information from children, use the Marzipan Services to serve ads to children, or use the Marzipan Services for any Property that is exclusively designed for, or exclusively directed to, children. Please note that, in the European Union, EFTA States, the United Kingdom, the State of California, and other locations as legally required, Publisher may not use the Marzipan Services to serve interest-based advertising to end users under the age of 18.

App developers under the age of 18

Marzipan’s terms and conditions prohibit app developers who are under age 18 from using our services as our customers.