What Developers Should Know About COPPA

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Contributions Industry Online

What Developers Should Know About COPPA

November 19, 2014 — by Industry Contributions

thumbnail — Tyler Smith, Director of Game Developer Relations, AgeCheq

Last year, on a scenic summer day next to the Susquehanna River, AgeCheq morphed from an idea into a company. Roy Smith, founder and CEO, had just finished some research on the new COPPA law that was put into place by the US Federal Trade Commission (FTC). Wondering how every game company that targets kids would be able to comply with this new law, he gathered his then three-man team together at their HQ (a picnic table). Everyone decided that this was a business that needed to exist to help the mobile industry work with the law. Tyler Smith, director of game developer relations, talks about COPPA and what to keep in mind as a developer.

What is COPPA?

The Children’s Online Privacy Protection Act (COPPA) was originally passed in 1998 and was put into effect in 2000. The initial intent of COPPA was to detail what a website operator must include in a privacy policy, dictate when and how to seek verifiable consent from a guardian or parent, and define what responsibilities an operator has to protect children’s privacy and safety online. This includes restrictions on marketing to users under 13.

If developers don’t comply with COPPA, they can get up to a $16,000 fine per user that is under 13, along with up to 20 years of privacy audits by the FTC.

If developers don’t comply with COPPA, they can get up to a $16,000 fine per user that is under 13, along with up to 20 years of privacy audits by the FTC. When you’re a developer serving millions of users, this can become a big headache fast.

The New COPPA

In the past five years, game developers have had to make a lot of changes in how they conduct business. From mobile gaming becoming one of the top grossing markets, to fighting for exposure inside the crowded app stores, adaptation has been key to pushing the industry forward. With all of this innovation in a burgeoning mobile space, the regulations on how business is to be conducted when concerning children grew outdated very quickly. This new shift in technology prompted the law known as the “Children’s Online Privacy Protection Act” or COPPA to be updated in 2013.

There are six main steps to the FTC’s newly updated COPPA compliance plan. Developers have to comply with each to make sure they aren’t in violation of the law. Let’s take a look at what the steps are:

Determine if your company is a website or online service that collects personal information from kids under 13
Post a privacy policy that complies with COPPA
Notify parents directly before collecting personal information from their kids
Get parents’ verifiable consent before collecting information from their kids
Honor parents’ ongoing rights with respect to information collected from their kids
Implement reasonable procedures to protect the security of kids’ personal information

In order to create great games for education and learning, as well as casual games that could be directed at kids, these new rules need to be followed.

The Big Six Breakdown

The first step is to determine whether or not your mobile game or app collects Personally Identifiable Information (PII) from any kids under 13. If you don’t collect any Personally Identifiable Information – which includes any unique identifiers like IP address or device ID – or if you have a foolproof method of making sure that kids under 13 aren’t using your game or app, you are in the clear.

If you are not, then the next step is to make sure to post a privacy policy. It must clearly and comprehensively describe how you handle personal information collected from kids under 13. The notice must describe not only your practices, but also the practices of any third party service or API your game or app relies on - like an advertising network or analytics package.

You may already have a privacy policy document. However, COPPA asks developers to tell parents specifically what PII your game or app collects. AgeCheq handles this by creating a database-driven layered privacy disclosure.

Obtaining verified parental consent is by far the most complicated step. The law defines four different ways that a parent can be verified.

Have the parent sign and mail in a consent form
Require the parent to do a monetary transaction through a credit card
Have the parent call a toll-free telephone number
Check a government-issued ID

Picture clipping 4 — Obtaining verified parental consent is by far the most complicated step.

At AgeCheq, we use the two most practical methods: a consent form, and a monetary transaction. After parents sign up for an account and verify themselves via one of these two choices, they are able to approve any privacy disclosures that are in their dashboard. We link the parents of children directly to the information they need to decide if the game controls its data collection.

Now, even if parents have agreed that you may collect information from their kids, parents have ongoing rights — and you have continuing obligations. Not only must you continue to give parents a way to review the personal information collected from their child, but you must also give parents a way to revoke their consent if they refuse the further use or collection of personal information from their child. Once they do that, you must also delete their child’s personal information from your databases.

Finally, the FTC’s plan requires that you establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children. This is all pretty common-sense stuff. Keep the data you collect secure.

This is a lot of information to digest, but hopefully you now have a better understanding of what COPPA means to the mobile gaming industry.

Knowing that there is a lot of information, Tyler welcomes questions about COPPA or AgeCheq’s solutions via his email at tyler@agecheq.com, or feel free to check out AgeCheq’s website.

Belgrade 2014 Live Coverage Video Coverage

Taras Leskiv: Bringing Digital Education Content to Eastern Europe | Casual Connect Video

November 18, 2014 — by Catherine Quinton

Taras Leskiv shares his experience with creating games for children during Casual Connect Eastern Europe 2014. And one of the lessons he has learned is, he says,”Children are the best QA!”

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As lead programmer at Nravo Kids, Taras Leskiv loves an intellectual challenge. As an English Language enthusiast, he spends his free time translating technical articles into his native language, and he is also a member of Coursera Global Translator Community. His other interests are startups, analytics, board games, and puzzles, balanced with the physical activity of table tennis.

His enjoyment in using his mind is equally apparent in his gaming. He is currently playing Dota 2 for the challenging mind games it is famous for. He also plays Skyrim because he enjoys the RPG experience and, as he says, “It’s great to have some rest.” He rarely plays any free-to-play games, preferring to buy full games from Steam and using a PC for his gaming.

A Focus on Children

Taras sees a lack of high-quality digital educational content for children in Eastern Europe and Nravo Kids is focused on filling the void by building a company that can provide this content with superior educational games for Ukrainian children. Taras notes that the number of mobile devices in Ukraine has been growing dramatically in the last several years, so the company is working actively with the community to understand what they would like to have on the market and how to monetize it.

Prior to working in the games industry, Taras worked for a company that provided English language courses. He has found the English he mastered there very valuable in his present work. He also spent a great deal of his time working with children, teaching English classes and conducting English master classes. This experience is critical in allowing him to understand the specifics of developing games for children. It also helped him with ideas for useful features and game improvements.

nravki_2 — His time working with children has been critical in allowing him to understand the specifics of developing games for children.

“My the most memorable teaching experience is from a summer English-speaking camp where I conducted master-classes about 7 Wonders of the Ancient World in English for Ukrainian children,” Taras says. “I had to gamify my classes to get children interested in the subject of ancient history and to teach them English at the same time.”

Working Hard

Currently, Taras is the only developer at Nravo Kids, handling all the development using the Unity 3D game engine. He is also responsible for the publishing process. “We are a really small and compact startup team that consists of six people for now,” Taras says. “So every team member has to be quite universal.” Since he had always wanted a career in game development, when the opportunity at Nravo Kids arose, he immediately joined the company.

ipad — The most gratifying time in his career came with the publishing of the first Nravo Kids game, Who’s in the Mountains?

The most gratifying time in his career came with the publishing of the first Nravo Kids game, Who’s in the Mountains?, on all major mobile platforms. With the initial idea of having a simple game, it soon became clear that the game would need to have more to it than planned. “The development was driven by the main goal - every aspect in the game has to be not only fun but also have educational value,” says Taras. As the only developer on this project, he successfully handled all the development as well as the publishing process to Android, iOS, and Windows Phone. Taras mentioned there were a few challenges when it came to wearing two hats, saying “it sometimes gets hard to switch between development and publishing contexts of the production process. Multitasking can’t get you focused at times.” But he looks at the bright side. “It’s a wonderful experience to develop a project from scratch to a final published title.”

Although Taras admits he is not particularly good at predicting trends in the games industry, he is expecting to see a major impact in the future from porting AAA titles like Bioshock and GTA from PC to mobile.

Video Coverage

Dr. Carla Engelbrecht Fisher on Children and Learning in the Gamespace | Casual Connect Video

August 19, 2013 — by Catherine Quinton

“Approach marketing like a record label,” said Dr. Carla Engelbrecht Fisher during her session at Casual Connect USA. “You know every time you’re buying that label what you are going to get.”

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Carla, Founder of No Crusts Interactive and long-time game design consultant, also recently made the transition to indie with the launch of her first game, Williamspurrrrg. Williamspurrrrg is a multi-touch iPad game where the player puts mustaches and hipster gear on cats. It was part of the Indie Showcase at Casual Connect USA, where she announced the launch of new levels of the game.

Hipster Cat — Williamspurrrrg is a multi-touch iPad game where the player puts mustaches and hipster gear on cats.

Until 2013, No Crusts Interactive was a game design consultancy. Carla still consults and lectures on game design, but the majority of her attention is on her new indie projects. In addition to Williamspurrrrg, she has two more games in development and a prototype for a new concept. To manage all this, Carla explains, “I have to be disciplined and methodical in all decisions, from how I spend my time to design and business development questions.”

Carla and her daughter — The time she spends with her toddler seems to offer a natural extension to developing for the family/kid space in the games industry.

Same Values, A New Direction
Carla tells us her work is driven by edufreude, a word she invented (inspired by shadenfreude) to describe the pleasure that comes from educating others. She brings amazing creativity and a varied range of interests to this work. She says, “My free time is largely game-related, which means I spend a lot of time on Flikr looking at cats, noodling with new game prototypes and researching and playing games.” She also admits to a weakness for “dystopian young adult novels and the TV shows Shark Tank and Dragons’ Den.” And the time she spends with her toddler building cardboard box forts and hosting stuffed animal pizza parties seems to offer a natural extension to developing for the family/kid space in the games industry.

Quality and Discoverability

Within this space, Carla believes discoverability is one of the greatest challenges, especially since not everyone has the spending power for user acquisition, ads, or other ways of garnering attention. A second large challenge is helping developers understand what makes good quality content for children. Because the barrier to entry is relatively low, new projects using outdated curriculum concepts are frequently seen. Curriculum standards and educational learning theories have evolved greatly, and developers need to be aware and use this latest information.

The best way for the industry to meet these challenges is through sharing information and experiences in centralized and accessible places.

The best way for the industry to meet these challenges, according to Carla, is through sharing information and experiences in centralized and accessible places. She continues to write and lecture extensively on all aspects of game design for children, from business development to design to marketing to discoverability options. She points to a number of agencies which are involved in defining quality content for children, including the Joan Gantz Cooney Center at Sesame Workshop and the Fred Roger’s Center for Early Learning and Children’s Media. She also encourages developers to share their stories and hopes to do more children’s product-focused post-mortem studies on her blog “Kids Got Game.”

Being Involved

In Carla’s business, she works to mitigate these challenges by sharing the details of her indie projects and encouraging her clients to share also. She continues to be very involved in exploring options for discoverability in the children and family market and points out, “The difficulty is that when children are the target audience, standard channels of discoverability and the usual business models are not always feasible. I’d love to fix this problem, but it’s not an easy road.”

Carla in France — Carla takes everything she has learned in her various roles and applies it to her own projects.

Carla tells us that, having taken the plunge into independent development, she is now in the middle of the biggest challenge of her career: building a studio and a brand in an incredibly crowded and competitive market. She admits, “The question is whether I can harness all of my experience for the past fifteen years and successfully do it on my own, but having made this shift, I find myself truly enjoying the experience of entrepreneurship.” She takes everything she has learned as designer, researcher, producer, programmer, consultant, community manager, writer, advisor, business developer and applies it to her own projects. She states, “I’d like to think that these experiences mean I am skipping the first generation mistakes and am headed for the second and third generation of mistakes, where innovation lies.”

Data, with its many powerful applications, especially in education, is the biggest trend that Carla sees affecting the game industry in the next few years. “Tracking and analyzing a child’s click-stream data means we can provide just-in-time assistance, rather than having to wait until the testing points.” However, she also sees privacy issues, particularly for children; it will take time to sort out the best way to collect and use the data. Her projects already incorporate data in small ways, but she is studying the market to find the opportunities that best fit her work.

With so many roles, Carla has had a lot of moments to be proud of. However, she experienced her proudest moment of her career after writing an article for Slate.com about being a victim of gun violence and a game designer. She wrote about why she had stopped telling people about being a victim of gun violence, but over the past year, discussions around media and violence has shifted, and she found herself wanting to speak out. Even so, she was terrified when she knew the article went live, having no idea what sort of reaction to expect. There were some difficult comments, but family, friends, colleagues, and even strangers proved to be a network of unyielding support. It created a level of dialogue she had never expected. It reaffirmed her belief that developers need to be involved.

Contributions Postmortem

Indie Showcase: Gamundo’s Club Galactik

March 20, 2013 — by Bart Eijk

Gamundo is a cross-platform game development studio formed by veterans of multiple ‘traditional’ game studios from around the globe. The company is committed to creating high-quality next-generation, accessible and commercially successful games. Gamundo’s talented core team members have produced three titles together; including the highly recognized browser based social MMO Club Galactik. In this postmortem, Ilja Goossens from Gamundo shares with us the story of how the idea for Club Galactik came to be.

The initial idea behind Virtual Fairground, my first true gaming venture, was to build online games for kids aged 8 to 12 based on existing IP. In 2007, my business partner and I were involved with a ‘traditional’ game developer and an online community company. However, we noticed a shift from console- and client PC gaming towards browser-based gaming (remember: this was before the whole Facebook/social gaming hype and before the iPhone was released).

At the time, there were some online communities for kids and some virtual worlds (the most successful turned out to be Club Penguin, acquired by Disney for $750 million). In order to become a top 3 developer of these online worlds, we had to come up with a strategy that would give us a head start. We had several options; (a) having a huge marketing budget, (b) using an important publisher or (c) using existing intellectual property. We decided to go for the latter, since this would allow us to get a user base relatively quick and to monetize aggressively.

Identifying the property

We knew that the conversion from offline to online was huge in this target demographic

With kids entertainment you have two different target audiences: the kids (who play the game) and the parents (who pay for the game). When kids start playing our game, they will love it and want more. This is when they have to start paying for a subscription or virtual currency. Parents tend to pay more quickly when they know the brand themselves, or at least heard of it before. Go figure: would you buy a product of an existing brand, like Apple, or from a no-name tech company?

We set some criteria that the IP had to meet to be useful for our plans. A must-have was television exposure, because from our own experience we knew that the conversion from offline to online was huge in this target demographic. For example, a friend of mine is a games publisher in the ages 8 through 14 target demographic (he used to publish Runescape, amongst others) and he had a barter deal with multiple TV stations. They aired the commercials for the show and they got a share of the revenue instead. He used this as the main driver for the audience and they saw huge spikes of registrations during the TV campaigns.

The IP also had to have traction momentum in the main European countries and optionally the United States. The property needed to appeal to both boys and girls in the age group 8-12 and was preferably created by an established brand like Disney, Nickelodeon, etc.

Based on these criteria, we identified a handful of properties. We did so by attending a lot of shows and (licensing) fairs, like MIP in Cannes (a TV licensing fair), the New York Toy Fair, etc. We narrowed the selection down to the properties that had potential and we added 3 properties that were a bit off, because they were based on a book, toy line and a magazine.

Building a relationship

To make it a really good deal, we will pay for the development ourselves!

Now we had to get in touch with the IP owners and make sure we could secure the rights for the online game, meaning we had to start networking like crazy. We were a small startup, pre-funding, with just a good idea. Again, we started visiting fairs and shows and trying to get in touch with the right people. These were the owners of licenses such as the Smurfs, Donald Duck, Charly and the Chocolate Factory and Winx Club. These were IPs that everyone knew and had an established value. Our pitch: we can contribute to the success of your IP, we will drive traffic to the offline components of the product and we will create an additional revenue stream. And to make it a really good deal, we will pay for the development ourselves!

Once we established a relationship with the IP owner, we could start negotiating the deal terms. Back in 2007 and early 2008, online game were not that hot yet. But we wanted to be able to build our own product, not just build what the IP owner wanted. This is why we did not continue the Disney deal (we were quite far in the process already).

Building a relationship with the IP owner is the most important there is

There is a funny story related to the Disney deal though. We knew the online director from Disney; he was located in Burbank, CA. We told him we were ‘in the neighborhood’, but we were not even in the US. After making an appointment for a casual chat and a cup of coffee, we booked a plane ticket from Amsterdam to Los Angeles and flew in just to meet with him. Building a relationship with the IP owner is the most important there is. If they have the idea that you know what you are talking about and can deliver quality, that will be so much more valuable than a bag of money. A brand like Disney cannot afford a mistake, a bad product or complaining customers. They fully need to believe that you can deliver what you promise.

In the end, a company like Disney has many, many rules and regulations for the IP, so in the end it felt more like we would be doing work-for-hire that we had to pay for ourselves, instead of building our own product.

We had some great ideas for potentially successful properties. After negotiating with the owners of IPs like The Smurfs, Charly and the Chocolate Factory and Donald Duck we settled with Alphanim. Our job was to create an online game based on Galactik Football. The show was a hugely popular cartoon series on Jetix, aired in almost entire Europe. At that point in time, two seasons had been aired and season three was in development. Besides, the show was about football and the World Cup of Football was coming up. Our timing couldn’t have been better.

Negotiating the deal

To close the deal regarding Galactik Football, we had to negotiate the terms. Of course, this is a very complex and lengthy process that needs professional guidance. We decided to hire an attorney that was specialized in intellectual property, so he could support us to get the best deal and warn us for the pitfalls. There are two main points to discuss: financials and content. The financial part is about (upfront) minimum guarantees, revenue share, and marketing- and development budget. This is a necessity, but can be pretty straightforward. The discussion about the content is a whole different aspect, here you have to convince the IP owner that you will do justice to their product, create length, create an additional value and can deliver a game with the same quality and look and feel as the original product.

During these negotiations, we established a very good relationship with the IP owner. Regular visits to each other’s offices and meetings with the marketing, creative and development teams were an important part of the process.

The concept for Club Galactik

The initial concept was to create an online game with lots of real-world extensions and a presence in the TV series. We would create a training school for talents and call it Club Galactik. To create the feeling that all players were also part of the TV show, we had written a story line in the script that contained the school. Now every player of the game immediately became part of the TV series. Together with the creators of the cartoon, we designed a logo, characters and a space ship that were used both in the series as well in the online game.

Alphanim would produce a trading card game, convince the broadcasting stations to implement the game into their websites, organize real life events and create connected merchandize. This way we would be responsible for the online product, and Alphanim would take care of the physical products and the marketing and distribution. Unfortunately for all parties, it didn’t become the success we all hoped for…

We depended heavily on the conversion from offline (TV) to online. Unfortunately, Disney acquired Jetix just before we released the game and decided to cancel the show because this was a third party production. (They rebranded the channel to DisneyXD and only programmed their own productions.) The IP was not strong enough to kickstart the distribution of the game, but we still had to pay a yearly licensing fee, so we decided to cancel the game even before the full version went live.

To see what projects Gamundo’s currently working on and what other games they’ve done in the past, have a look at their website.