United, Delta, and OpenTable got a note from California Attorney General warning them that they are violating The California Online Privacy Protection Act. According to the COPPA, any online application that collects user's personal information must conspicuously display a privacy policy. Without compliance to the COPPA companies can face $2,500 fine for every violation.
This got me wondering how United, Delta, and OpenTable violated the COPPA. What exactly did United, Delta, and OpenTable do or not do?
DISCLAIMER: Before I share my findings, I want to disclose that I do not hold law degree, and I do not claim that recommendation that I'm about to give will satisfy the compliance to the COPPA. Use my recommendation at your own risk of getting a letter from Kamala Harris.
Ok. Now that I've gotten that disclaimer out of my way, let me share what I've found.
If you are running a social network service, you should know that the COPPA applies to your service because most social networking sites store user's personal information. You need to have privacy policy available from your website.
What's interesting with Kamala Harris' warning to the companies is that she's now extending the COPPA to mobile applications. That means mobile application users should be able to read privacy policy before they can download the application and start using it. The key is before downloading and using the application. The most natural place is on the application download page on App Store.
Most people don't bother scrolling to the bottom of App Store application page, but here's what you can see from Facebook, which is cited as the COPPA compliance mobile site.
When you click on Privacy Policy link, it directs user to Facebook Data Use Policy page.
What about the other companies that are cited?
Let's look at United.
Their app page does not link to Privacy Policy page. It turns out that United already has Privacy Policy page. It's just not linked from the app page.
What about OpenTable? They literally missed the URL by a dot.
Moral of the story: Specify Privacy Policy URL when submitting the app to App Store and make sure you are linking it to the right URL and the link actually works. It will help you avoid a call from California Attorney General's office.
This got me wondering how United, Delta, and OpenTable violated the COPPA. What exactly did United, Delta, and OpenTable do or not do?
DISCLAIMER: Before I share my findings, I want to disclose that I do not hold law degree, and I do not claim that recommendation that I'm about to give will satisfy the compliance to the COPPA. Use my recommendation at your own risk of getting a letter from Kamala Harris.
Ok. Now that I've gotten that disclaimer out of my way, let me share what I've found.
If you are running a social network service, you should know that the COPPA applies to your service because most social networking sites store user's personal information. You need to have privacy policy available from your website.
What's interesting with Kamala Harris' warning to the companies is that she's now extending the COPPA to mobile applications. That means mobile application users should be able to read privacy policy before they can download the application and start using it. The key is before downloading and using the application. The most natural place is on the application download page on App Store.
Most people don't bother scrolling to the bottom of App Store application page, but here's what you can see from Facebook, which is cited as the COPPA compliance mobile site.
 |
| Left is Facebook app page. Right is what gets displayed following Privacy Policy link. Source: Facebook app page on App Store |
What about the other companies that are cited?
Let's look at United.
 |
| Following the Privacy Policy link leads to nowhere. What has to hurt for United is that they have Privacy Policy page: http://www.united.com/web/en-US/content/privacy.aspx Source: United app page on App Store |
What about OpenTable? They literally missed the URL by a dot.
 |
| Ouch, that's gotta hurt. Missing one dot and getting all the negative publicity. Source: OpenTable app page on App Store |
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