Last update: October 2021

4 mins to read - 2021/10/06

Best Practices Towards Marketing to Children Online

The world is changing rapidly. The things our mobile devices are capable of are advancing so quickly that guidelines and regulations can barely keep up. This can be problematic when it comes to the realm of mobile marketing, and what exactly it’s legal for companies to do with our personal data. And even more so when it comes to best practices – what is and isn’t safe – for marketing towards children.

With nearly all toys or media aimed at kids having some sort of digital or mobile app component, it’s important to make sure you’re doing your due diligence and staying COPPA compliant, both to avoid FTC fines and to ensure you’re maintaining the trust of your users and their parents. Not only should your brand make sure any software or tech it’s using is fully compliant with local privacy regulations, but privacy and transparency should be baked into the ethos of your brand and how you interact with users. Here are some tips for ensuring your digital marketing campaign is up to code and engaging respectfully with users of all ages.

Download our Data Security Whitepaper to learn more about OpenBack’s innovative approach to data privacy:

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ICPEN’s Best Practice Principles for Marketing Practices Directed Towards Children Online Report

In 2020, the  International Consumer Protection Enforcement Network (ICPEN) published a report on the best practices for digital marketing towards children. While most mobile apps look to a particular regulation, such as COPPA or GDPR, for guidance on how to approach the leverage of kids’ data for marketing purposes, the ICPEN article takes more of a high-level approach.

With They categorized their existential concerns about the state of digital and mobile marketing towards children into 4 groups:

  1. Transparency as to what content is commercial versus non-commercial
  2. Marketing that exploits children’s lack of experience or naivity.
  3. Data privacy: who is accessing kids’ data, and what’s being done with it
  4. Inappropriate products/services being marketed towards kids

First and foremost, digital marketers must determine whether their marketing content is directed at children. COPPA has its own framework for determining this, but a good rule of thumb is whether the content has bright colors, or features cartoon characters that are likely to appeal to children. The 4 concerns listed above, it then reworked into 4 guiding principles for marketers to follow.

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1. Ads Should Be Transparent and Straightforward

It’s crucial for users of kids’ apps to be able to tell the difference between what is advertising and what isn’t. As consumers have become more savvy and more fatigued with marketing, marketing has had to adapt and become more creative in its methods. This has led to techniques such as native marketing, in which an ad is camouflaged as, for example, a social media post in your newsfeed.

Influencer marketing is another technique that kids might not fully realize is designed to sell them things… with less experience than adult consumers, kids are more likely to think an influencer is making them genuine suggestions, without ulterior motives.

In-app advertising is another tactic that blurs the line between marketing and content. Advertising that’s incorporated into games can be especially difficult for children to distinguish, especially if it’s designed to look like a mini-game, or if kids are being rewarded with in-game currency. As a best practice, responsible in-game marketing should be straightforward and easy for children to recognize as an ad.

2. Do Not Use Kids’ Credulity or Lack of Commercial Awareness

There has been a lot of debate in the mobile app industry around marketing techniques that may be taking advantage of minors. Among these, loot boxes in mobile games have been especially controversial, and have even been banned in some countries, due to their randomized prizes that can be especially addictive for kids.

This moreover unveils a certain grey area when it comes to in-app purchases in general for kids’ apps and game. On the one hand, IAPs are one of the primary means of monetizing free-to-play (F2P) apps or games. This particular business model has revolutionized the digital arena in general and the mobile app industry in particular. Apps and games are accessible in a way they never have been previously. 97% of Google Play apps and 94% of App Store apps are free to download, with mechanisms for microtransitions so you can “pay as you go.”

It is important to consider exactly how your app is monetized, in this case. While most parents won’t object to some in-app purchases in games or apps their kids are using, make sure they’re there to augment the game’s UX – not hold it hostage. Your service’s utility should not be tied to its user making regular microtransactions.

3. Don’t Market Inappropriate Products or Services to Kids Online

This goes without saying. You should not be sending kids marketing material for products that are harmful for them – tobacco, alcohol, gambling, adult material, etc. Not only is it illegal and unethical, it’s also a waste of your marketing budget, as there are safeguards against children purchasing such products to begin with.

4. Data Privacy: Kids’ Data Should Not Be Collected and Used for Harmful Purposes

This goes without saying, and the FTC’s COPPA covers this at length. And with Apple’s recent introduction of App Tracking Transparency, where all device users have the option to veto having their data tracked and sent to 3rd parties, things are changing at a macro-level for the mobile advertising industry.

That being said, while more users are becoming aware of the potential for their data to be used for harmful means, this also means there is more of a dialogue going on about how data can be processed to improve app or game UX. For example, games like Pokemon GO and other augmented reality apps depend on leveraging users’ geolocation data to show app users where to catch Pokemon, or where they can team up with other players to go on a raid.

OpenBack’s mobile engagement platform, which uses device-side data processing instead of sending user data to a 3rd-party cloud. It is therefore 100% COPPA compliant by default, and your best bet when it comes to delivering highly personalized mobile push notifications while remaining regulation compliant. (This is why so many leading kids’ apps use OpenBack as their push platform.)

In addition to using OpenBack, other best data privacy practices for responsible marketing towards children include keeping an up-to-date privacy policy in an easy to access part of your website. Be direct and forthright about why you need to process user data, and how that improves app UX. And include a framework for deleting any user data upon request.

To learn more about how your kids’ app can be COPPA compliant while sending highly personalized notifications with OpenBack, get in touch with one of our experts.

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