Children’s Online Privacy Law Compliance

General Information

The Company makes best efforts to comply with applicable Children’s Online Privacy regulations, including the US Children's Online Privacy Protection Act of 1998 (COPPA), and minors data protection requirements in the EU (each, or jointly “Children Protection Regulation”). Publishers must comply with any and all applicable Children Protection Regulations, and shall actively instruct the Company as for the nature of its App(s) and the audience it targets. This includes, without limitation, the following requirements:

• Upon onboarding, Publisher shall report to Company and update on an ongoing basis, the nature of the App(s) and the audience it target(s) in accordance with the then-current categories provided in the Publisher Portal, as follows: Children/non-Children directed.
• Children/non-Children directed flags shall also be provided with any single Ad Request as defined under Applicable Children Regulation (i.e., Under 16 in the EU, under 13 in the US, etc.). 
• In case the Ad Request is Children Directed, Publisher shall make sure to have a mechanism in place to avoid of: (i) personal information processing and (ii) presenting questionable content (as defined in the App Store’s terms, conditions and guidelines). 

How To Declare if the App or Ad request is Children Directed

1. App level Children Directed declaration

When creating or editing an app on the display.io Publisher Portal  you can declare if your app is Children Directed by choosing Yes/No for the following parameter:

Children Directed (COPPA and GDPR compliance)

• My application is specifically directed to children under 13 years from USA and/or under 16 years from Europe.
   And/Or
• I have actual knowledge that my application has users from USA known to be under 13 years and/or from Europe known to be under 16 years.

An app may be considered child-directed based on a variety of factors, including the following examples:

• The subject matter of the app (e.g., game)
• Visual content (e.g., candies)
• Use of animated characters
• Presence of child-oriented activities and incentives
• Type of music or other audio content (e.g., songs sung by children, not just songs that kids like)
• Age of models (e.g., babies, toddlers, tweens)
• Presence of child celebrities or celebrities who appeal to children
• The complexity of language used on the app

If you are unsure about whether your app is child-directed, please seek legal advice.

2. Ad Request level Children Directed declaration

Within Ad Request in order to define if the user is a child according to the local law (USA, Europe, others):

• For SDK iOS:
  

  [properties setChildCompliance:DIOComplianceYes];

  Available values: DIOComplianceUnknown (default), DIOComplianceYes, DIOComplianceNo

• For Android:

  initProperties.setChildCompliant(CompliantState.YES);

  Available values: UNKNOWN (default), YES, NO
  
  

How it Affects Bidding

If on Ad Request level you declare that a current user is a Child or the user's status is unknown, but the application is Children Directed based on the settings on Publisher Portal, then:

    1. The following data will be removed from the ad request:

• device ID (advertising ID);
• geo location: lat/long;
• gender;
• year of birth;
• user (personal) keywords;
• IP address.            

    2. We will ensure that you will receive an ad appropriate for Everyone, inc. children.

Please note that this may significantly impact the monetization potential of your traffic !