Meru Data's Podcast
There is tremendous value to simplification. To quote Steve Jobs, “Simple can be harder than complex: You have to work hard to get your thinking clean to make it simple. But it is worth it in the end because once you get there, you can move mountains." In this series, we explore how people and companies achieve simplification.
Meru Data's Podcast
Children's Data and App Store Accountability Laws
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Children’s privacy is rapidly evolving beyond traditional COPPA compliance. New state laws, expanding FTC enforcement, age assurance requirements, and app store accountability measures are reshaping how businesses manage data related to minors and teens.
In this episode of Simplifying for Success, Priya Keshav, Founder and CEO of Meru Data, is joined by Nerissa Coyle McGinn, Partner at Loeb & Loeb LLP, to discuss the changing regulatory landscape and what businesses need to do to prepare. The conversation covers key enforcement trends, emerging age verification requirements, app store accountability laws, and the growing expectation for organizations to address children’s privacy through governance and operational practices.
Topics Covered
- Expanding FTC enforcement and its impact on children’s data
- State age assurance and age-appropriate design laws
- App store accountability requirements
- Key lessons from recent enforcement actions
- Age verification, parental controls, and compliance challenges
- Practical steps businesses can take to prepare for evolving requirements
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Priya Keshav: Hello, everyone. Welcome to our podcast, Simplifying for Success.
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Priya Keshav: In each episode, we explore how leaders can bring discipline, clarity, and practical structure to complex areas of privacy and governance, AI governance.
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Priya Keshav: Simplification is always not easy, especially in today's fast-moving regulatory and business environment. So we invite experienced colleagues in privacy and AI governance to share how they approached these challenges in practice. Before we get started, I'm Priya Keshav.
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Priya Keshav: And I'm one of the founders and CEO of Meru Data. At Mero Data, we help organizations simplify operational and operationalize privacy and AI governance programs worldwide.
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Priya Keshav: Our work focuses on building privacy by design practices through technology, implementation, process optimization, and practical governance.
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Priya Keshav: Before founding Meru Data, I served as a managing director of KPMG's forensic technology practice in the Southwest US. I also regularly speak, write about emerging trends in privacy and AI governance.
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Priya Keshav: Today, I'm delighted too. I invite our special guest, Nerissa Coyle McGinn.
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Priya Keshav: Welcome to the show, Nerissa!
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Nerissa : Thank you!
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Nerissa : Thanks for having me.
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Priya Keshav: To begin, could you tell our listeners a little bit about yourself, your practice, and the work you're doing in the children's privacy advertising and digital platform accountability space?
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Nerissa : Sure, well, I am, a partner, at Loeb & Loeb, and I specialize in,
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Nerissa : advertising, privacy, and emerging technologies. So,
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Nerissa : Under that, you know, a lot of the information that is collected is collected for advertising and promotions purposes, and… which is why we have such a robust, privacy practice.
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Nerissa : And we also
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Nerissa : really focus on, different types of emerging technologies, including AI. So, one of my areas of specialty in, in privacy, in particular, is, children's data. And, the collection of children's data
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Nerissa : And I work with a lot of different clients, small and large, related to their collection of information from, now, not only children under the age of 13, but also minors.
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Priya Keshav: So today, we're gonna talk about a very timely and an important topic, children's data and app store accountability laws.
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Priya Keshav: Maybe we should start with why this topic matters now. Children's data has moved from a very narrow COPA issue to a broader,
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Priya Keshav: accountability, safety, and product design issue. What do you think has changed in the regulatory environment to make children's data such a high priority right now?
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Nerissa : Right. I, want to commend you. This is the perfect time to be bringing up children's privacy. I think you're right. Like, this used to be, very COPPA-focused.
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Nerissa : COPPA came out, I believe it was 1999, which was so long ago, that
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Nerissa : it really was a completely different internet. Like, we didn't even have social media back then. And I think we're really at a precipice now, where there have been a lot of laws that have been passed.
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Nerissa : Some of them are in effect, some of them aren't, but they're starting to go into effect in a way that is well beyond COPPA, so this is a great time to be looking at this… at this topic.
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Nerissa : You know, I really think that children's data has moved from a, like, a more narrow COPPA to a broader, really a broader, law within COPA itself.
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Nerissa : Right? For two specific reasons. The first reason is that we just had an amendment to the COPPA rule by the FTC. So, it was amended last year, and then it went into effect last year, and now the enforcement started as of, as of April. So, we haven't seen anything yet, but we probably will soon.
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Nerissa : The, the amendments to the rule that happened, to the COPPA rule, really kind of took
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Nerissa : all the cases that we had had over, you know, since the last, you know, several years, which had really expanded the COPPA rule and how it was interpreted, and, solidified them within the rule.
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Nerissa : It really is there were a couple of things that happened with that.
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Nerissa : The first is that it really broadened the scope of what the types of websites that, they that the FTC was looking at.
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Nerissa : They are no longer really just kind of looking at that very specific
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Nerissa : website that is, just directed towards children, like Paw Patrol or something like that. It's much broader now. They're looking at these mixed audience sites, and we now have a definition for what a mixed audience site is.
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Nerissa : And so these are sites that are really, you know, are going to have kids under 13 and older, older users.
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Nerissa : So it really started is starting to try to pull in some of these some of these websites that, for a long time, I think the websites were like, hey, we're not directed towards kids, we don't fall under COPPA.
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Nerissa : The other thing that I think has happened is that, we've had a change in administration with the FTC, right? You know, we just had a Supreme Court ruling, yesterday.
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Nerissa : that, one of the FTC commissioners, Rebecca Slaughter, can be fired, that she's an at-will employee, and can be fired by the executive branch, really whenever they want to fire her. And so the FTC has started to become
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Nerissa : More of a political A political beast.
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Nerissa : than it was before. And you can go you can see that it is doing that. You know, not in this area in particular, in children's privacy, but with AI,
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Nerissa : This FTC actually went back to the Biden administration decisions and overturned them.
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Nerissa : For one of the AI decisions. So you're really seeing that there's a change, and that this FTC is particularly focused on children's privacy. It's something that they are very concerned about.
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Nerissa : And they really want to make sure that they are protecting children, and that they're doing it in their own way. You know, they're… they… I think…
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Nerissa : The greatest example of this is there was a workshop that was planned right after Trump took office. That got rescheduled twice.
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Nerissa : And really, the entire focus of it changed. They took big tech out of it, and they brought in a lot more, advocates about protecting children.
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Nerissa : And they're
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Nerissa : Definitely focusing more on, things like making sure that there's age gates and, age verification, and that websites can verify who their users are, so that they're not, you know, collecting information from children.
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Priya Keshav: So the states are also ramping up, right? Like, we're seeing a growing wave of age verification, age assurance, age-appropriate design law across states such as Utah, Texas, Louisiana, Virginia, Maryland, and Vermont. What do these laws mean for companies operating nationally? And, you know, how do you see that sort of play with you mentioned the FTC and their focus
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Priya Keshav: On children, so how does, all the, you know, laws within the states comp… do they complement, or
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Priya Keshav: How do you think that plays out?
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Priya Keshav: At the state level.
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Nerissa : the law the state laws are, much broader than what you have, federally in COPA.
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Nerissa : And, you know, I kind of like to think of them in, these laws
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Nerissa : in different buckets, right? And that one of the buckets is going to be these age assurance laws that you're talking about. Then you also have another bucket is these, age-appropriate design codes.
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Nerissa : and you also have just these… you know, a third bucket is gonna be these general,
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Nerissa : Children's or general privacy laws that, are now protecting not just children, but teens.
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Nerissa : You know.
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Nerissa : the laws are directed towards different types of companies, depending on which bucket you're talking about. And so I really think how you try to comply
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Nerissa : and operate nationally depends on the type of website that you're that you have. If you have
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Nerissa : For instance, you have, a website that is directed towards children.
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Nerissa : And when I say directed towards children, I'm talking it's much broader than the directed towards children that we used to see under COPPA. They're gonna be looking
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Nerissa : You could have very few users and… that are under the age of 13 and still be considered directed towards children. Some of the some of the state laws are even saying as low as 2% of your users.
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Nerissa : So, if you are,
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Nerissa : If you are a company that is directed towards children, you are going to have to comply with all these different age-appropriate design codes.
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Nerissa : That are out there. And it's gonna be much more burdensome for those companies, because they're going to have to change their… the functionality of, for instance, their apps.
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Nerissa : They're going to have to make sure they have the default privacy settings. There are certain tools that some of these… some of these age-appropriate design codes
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Nerissa : are requiring, so it's gonna be very difficult for them. I also think
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Nerissa : You know, the other bucket of companies
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Nerissa : is gonna be companies that have mixed and what they are calling kind of general audience sites, right? Because a lot of those general audience sites probably
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Nerissa : are going to have users that are under the age of 13, so, or under the age of 18, at the very least. You know, these sites might not have to comply with those age-appropriate design codes.
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Nerissa : Right? But they are going everybody's gonna have to comply with these age assurance laws that we're seeing, and the app store laws. And there, all of a sudden, they did not know that their users were under the age of 18, which has a whole bunch of…
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Nerissa : Additional requirements associated with it, and now they're gonna know.
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Nerissa : And that's gonna, mean that they're gonna have to, you know, change probably change at least how they're collecting and how they're siloing their their users.
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Nerissa : You know, the only ones that I think are gonna have a problem are websites, like, that are obviously for people that are over the age of 18.
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Nerissa : Right.
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Priya Keshav: So, with these emerging frameworks, like the California Digital Assurance Act coming into effect next year, how should companies think about, you know, as they are thinking about
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Priya Keshav: implementing, you know, different practices, or at least accommodating, or segregating children. So what should they do to kind of have… how should they handle collection?
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Priya Keshav: verification and managing age-related data that needs to be collected for them to understand how many are below 18, right? So, how do you sort of… what do you recommend for your clients?
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Priya Keshav: Typically.
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Nerissa : Well, I mean, I think that if you're talking specifically about the collecting and verifying and managing of age verification, you know, the collecting is going to start to become a lot different.
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Nerissa : I think a lot of clients are, right now, potentially not collecting the user's age, right? And now they're going to be required, under these app store laws, and then the California Age Assurance Law to, at the very least, collect the
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Nerissa : The, the user's ages from the app stores or the operating system.
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Nerissa : So, that they're gonna have to look
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Nerissa : And prepare, and these laws are going into effect now. You know, technically the Texas one is in effect. I don't, you know, it may… that may change. We're waiting for what the Supreme Court says.
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Nerissa : And then you have two, you know, at least, you know, the California, there's two more that are going into effect as of January 1st.
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Nerissa : So, you're gonna have to figure out, and our clients are we're telling our clients to figure out how they're going to ingest these APIs.
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Nerissa : to get this information. The verifying isn't gonna be that much is gonna be pretty easy, because you're, for the most part, just going to take the age that's given to you by the App Store.
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Nerissa : And so that's not going to be as much of an issue. I think the hardest part is, I think, your last part of the question was managing. Managing this information. You know.
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Nerissa : That is gonna be the part that is gonna… going to be very difficult for a lot of
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Nerissa : Apps, apps, because they don't know that their users are under the age of 18.
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Nerissa : Per se, right? They might they might guess that they have a bunch of users under 18, but they don't know which users they are, and now they're gonna know, and they're gonna have to follow all these laws that are out there, not just, you know, the age-appropriate design code laws, but a lot of these, you know, general children's
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Nerissa : General general privacy laws, comprehensive privacy laws, and these, other children's privacy laws that aren't going to allow them to collect or use information in certain ways.
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Priya Keshav: Yeah, so, adding just a note in the privacy policy saying that we're typically most of our customers are about 18, wooden surface, you have to collect the data.
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Priya Keshav: verify and figure out how to manage it. So that's… that's definitely a big change for many companies that I think, you know, are…
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Priya Keshav: may have children's data, but are not currently monitoring for kids' data.
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Nerissa : Time oh, I'm sorry. I was just gonna say the exactly exactly what you're saying. The time of when you could say.
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Nerissa : we're just gonna up the age in our privacy policy to 18, and then put our heads in the sand. That's over now.
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Nerissa : Right? Like, that's not gonna exist in 6 months. And people have to get ready for that, because now they're gonna know, and they'll they'll have to silo the 18-year-old separately, or create a separate app.
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Nerissa : for or experience for the people that are, under 18, so that they can still use their app. But I think you're exactly right.
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Priya Keshav: So, you know, once they know that they do have
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Priya Keshav: You know, customers who are below 18, who are using their products and services.
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Priya Keshav: What do you see are the trends that are emerging across these state laws, right? In terms of, are the states moving towards similar concepts of what they want the companies to do, or are we seeing materially different approaches to children's handling children's data, teen data, parental consent, and online safety? Like, what do you see are the trends across states?
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Nerissa : I would say that it's materially different, but there are some themes that are out there, right? So, like, even the age of how old people
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Nerissa : are when they start to get these additional protections, is changes from state to state. What information is protected can change from state to state, and how you can use that information.
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Nerissa : You know, but I think we are seeing some general trends.
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Nerissa : You know, you have these comprehensive privacy laws, that and those are giving protections to teenagers and, you know, up to, really, 18.
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Nerissa : Depending on the state. And those are generally requiring some type of either opt-in or not allowing the processing of information.
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Nerissa : Of, of minors, depending on what that age is. You have these age assurance laws that you're seeing.
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Nerissa : That are really kind of… that are requiring and giving
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Nerissa : apps the knowledge of how old their users are, and then you have
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Nerissa : these design code laws that are going to be very burdensome if you have users that are now that you know that you have users under the age of 13, or under the age of 16 or 18, depending what
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Nerissa : How old that that law protects, that are… is gonna require changes to your
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Nerissa : Like, tools for parents to be able to monitor the use of their their child's use of the app, and better notifications for parents, such as, like, signals when you're collecting certain information for the kids.
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Nerissa : And making sure that the parents understand what is being collected.
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Nerissa : And then also default privacy settings. So there's a lot of things that are going to be required under those age-appropriate design codes that people are ignoring right now.
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Priya Keshav: And so some of the decisions that they need that customers will have to, or companies need to make is, to think about whether they're going to standardize at a certain, you know, level of like, for example, if there's significant differences, whether they're going to standardize at
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Priya Keshav: 18 for everybody, or are they going to provide, you know, exactly what is being mandated by each state? So these are questions that they have to ask and figure out what's the right path. With so many overlapping laws, and I also want to kind of point out that it's a it's also experience, right? Like, I live in Texas, and I so see some design changes. My teenage daughter was just asking me this morning.
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Priya Keshav: is there any way you don't have to get notified about some things? And I was like and she was asking, why did I change the settings? And I was like, it wasn't me, but basically, Apple decided to make those changes, so, you know, I'm notified, when she makes certain, you know, decisions about various apps, and so it was interesting to her, like, that I, you know.
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Priya Keshav: we were having this conversation, and she was like, why are you monitoring me? And I was like, no, I wasn't monitoring her, but it was a change that happened because of the laws. So
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Nerissa : Apple is, and the Texas government.
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Priya Keshav: I'm saying you're.
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Nerissa : I have to monitor her.
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Priya Keshav: Yeah, but it's, it's a, it's a, it's an interesting conversation, and today, as I was doing this podcast, I was just recollecting that conversation, and she was obviously, not happy, but
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Priya Keshav: I mean, it's something that also affects user experience, because, you know, the parents have to know how to that there are changes, the teenagers will have to know there are changes, and so it's a lot of complex things that needs to be taken care of as they look at product design.
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Nerissa : It's gonna make it a lot harder for
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Nerissa : not for the kids to use the use their phones, but also parents. It's gonna because you're gonna have to be approving a lot more.
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Priya Keshav: Yeah, so she was we had we had a big event over the weekend, and there were people texting her, but she… she wasthey were not in her contacts, and that's kind of what happened, so she could not reply back, because I had not approved, and I was busy running around, so…
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Priya Keshav: Obviously, I didn't look through those, you know, messages that came to me and approved them as, you know, contacts for her. So, yeah, it's definitely a lot of change coming for, not just the companies, but also those who are using the apps.
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Priya Keshav: So many overlapping laws, is there any realistic path towards standardization? I mean, as you kind of…
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Priya Keshav: I'm sure there are people asking you questions as to should they assume that they, you know, should they assume some level of standardization, but with that, or should they keep the complexity intact?
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Priya Keshav: Because, you know.
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Priya Keshav: is it's not a short-term change that is happening. This these changes around children's data is probably there for the longer term, right? But what what do you advise your clients, and what are your thoughts around how they should standardize?
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Priya Keshav: I'm sure every company is different, every app is different, but to the extent that we can talk genetically, yeah.
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Nerissa : Yeah, I don't know that we're… if… There's gonna be any realistic path.
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Nerissa : towards standardization, like, that there's going to be, like, one comprehensive law, out there. I know that we've been,
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Nerissa : we
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Nerissa : I know that what we have seen is that, you know, the federal government has tried to pass a law a gazillion times.
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Nerissa : Right? And
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Nerissa : They have a whole bunch of pretty much every one of the state laws that I've been talking about, the app store laws, the age-appropriate design code, the upping of the COPPA protections, all of those are laws that have been proposed in Congress and for years have not been able to get through. So there's gonna be no standardization. So really.
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Nerissa : I mean, without standardization, I think that you have to
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Nerissa : Understand what all the laws are, and kind of find the lowest common denominator for
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Nerissa : each of them, and make sure that you're, you know, applying, if they're complying with them. So, you know, what's the hard you know, what what do you, like, what type of default privacy settings are you gonna have? You're gonna have to do that everywhere. What types of tools do you have? You have to do that everywhere.
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Nerissa : I think the hardest part is possibly some of these app store laws. They're really kind of
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Nerissa : They're rolling those out everywhere, but each state has, like, especially on how the
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Nerissa : apps get the information, the age verification information, how it's technically done and when they can do it is a little bit different. So those are gonna that's gonna be a little bit a little bit harder, but
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Nerissa : You're just gonna have to know all the laws, and you're gonna have to find the lowest common denominator for each of each each different element of them.
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Priya Keshav: So let's talk a little bit about the app store accountability laws, right? These laws are shifting some responsibility to app stores and platform providers. What role are app store policies beginning to play in enforcing age-appropriate design and compliance standards?
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Nerissa : I don't know if the policies are changing to make sure
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Nerissa : that the apps are, complying, per se. I mean, what the laws are saying is that the app stores have to have this functionality, and they have to make it available. And so then it's going to be on the individual users, at least so far.
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Nerissa : to make sure that they can ingest those apps, right? So I think that you are seeing changes with the App Store policies. Like, you've seen
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Nerissa : changes with the age ratings for some of these app store app stores, to comply with the different laws and to make it, like, have the same age rating as the laws, have. They,
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Nerissa : There there's going to be, you know, obviously some,
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Nerissa : Policy changes on how they're, you know, how someone signs up for,
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Nerissa : how someone signs up for an account, like your Apple account.
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Nerissa : And then how they're pushing out the age. There's gonna be policies associated with, like, every time you update your app, you're going to have to tell, the app store, and then they're gonna have to get consent again. So there's going to be a lot of policies associated with how those things are going to work.
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Nerissa : But I think that some of them will, you know, the app
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Nerissa : The app store is obviously… and this is a huge burden on them, and they've been preparing for it, but sometimes some of the information related to how some of these things are working is trickling out very slowly, from what I can tell.
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Priya Keshav: Yeah, and I think, you know, we talked a little bit about this, but this is going to not just affect app stores, right? So, with… as they change their policies, the developers have to figure out how to appropriately change.
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Priya Keshav: according to the App Store policies, and change their behaviors in terms of they the apps will have to receive the CH, do the verification, and the parents and the miners have to sort of understand that there's going to be changes to the way they have been interacting with the apps.
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Priya Keshav: And all of that is going to become, completely different as we sort of look at,
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Priya Keshav: as the App Store laws go into effect. So.
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Nerissa : it's gonna become very difficult exactly what you said, and what happened with your daughter. It's it's gonna be you know, kids are gonna try to download an app, they're not gonna be able to download the app right away. They're gonna have to talk to their parents, and then there's gonna have to be a notice, and the parents are gonna have to approve it. Parents don't approve things right away.
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Priya Keshav: No.
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Nerissa : And, you know, if there's a change to the app, they have to approve the change to the app. If there's a purchase within the app, they have to approve that.
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Nerissa : The California law is a little different, right, Ed, where there aren't all these required,
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Nerissa : You know, parental, consents.
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Nerissa : It's more like, hey, we're telling you that this kid is…
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Nerissa : is 17, and now you have to comply with all the California laws that relate to a 17-year-old. And
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Nerissa : But you also have to realize that California is one of the only states that has gotten their age-appropriate design code partially through.
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Nerissa : Right? And there are a lot of requirements related to that age-appropriate design code that are going to kick in because, because of the fact that, you know that that person is that user is a minor.
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Nerissa : That's gonna that's and that's gonna cause a lot of issues, I think, you know, for these
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Nerissa : for for these app developers. Also, the California
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Nerissa : the California, age assurance law is not just for app stores. It's for any type of operating system, so it's much broader. It's operating systems for computers, it's operating systems for watches, it's operating systems, where they have to, send out this
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Nerissa : this age. So if there's an app that's on a watch that maybe isn't in the in the Apple App Store, that still is is going to, going to have to you're still going to have to have these this functionality, and the collection of the age, and then passing it on to the app provider.
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Priya Keshav: And it's not just App Store, right? So what about, like, devices like Roku, or
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Priya Keshav: Fire, Box, or like, there are many, many other places where apps reside, and they will I mean, even cars, apps, and so this kind of extends to any kind of
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Priya Keshav: devices like that as well, right?
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Nerissa : device, right? As compared to the earlier laws, the app store, which are called app store laws, those are your mobile app store. That is Apple and Google, right? So, those are pretty but the ones that we were looking at, these are operating systems, like.
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Nerissa : California is any operating system, so you're right, like, Amazon has an operating system that is within
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Nerissa : the fire, or and you can get apps within it, that now falls under under that, because it's not just a mobile device, it's also the device that you stick into your into your into your TV.
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Nerissa : Right? So, yes, it's the California law is much broader, and because it just says, okay, now you have the age.
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Nerissa : Now, app developer, you have the age, and you have to comply with whatever laws are out there, and it doesn't have all these consent requirements, and sending in changes to your… to your app, things like that.
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Nerissa : I think that the concern is for developers and these operating systems is that it's going to be harder to strike down this law. It's going to be harder to get an injunction to stop it, so it's more likely that it's going to go into effect on January 1st.
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Priya Keshav: Are there any other specific operational challenges that you see for the developers as they kind of look at practical compliance beyond what we just talked about?
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Priya Keshav: I feel like there's some benefit to centralizing the age verification, with these operating system providers and app store providers, because to some extent, that was… I mean, it's still a debate, because now you're passing age to everybody. I think…
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Priya Keshav: both ways, it's a problem. You know, you're disclosing too much information, but not disclosing information exposes children to a lot of risk as well, so there is no perfect answer. But what do you think are some of the operational and legal challenges that developers may face by when they start implementing and receiving this information from the
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Priya Keshav: For various devices, so
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Nerissa : Yeah, I mean I think that There's the obvious The obvious ones
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Nerissa : that once they receive the information, like, for the for the for the app store laws, the app store laws, not the California age assurance laws, there's gonna be a lot of operational issues associated with that, because it's not, like.
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Nerissa : You know, it's not only that you're ingesting that, that age, and you have to get consent, but then there's going to have to be continuous consents associated with the, purchases within the app.
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Nerissa : and, any type of changes to the app. So, you know, it's not gonna be like you're just gonna change your privacy policy or terms of use. It's like, we're gonna change our privacy policy in terms of use, and if it's a material enough change, which, you know, the changes that are
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Nerissa : that are discussed, you know, within these laws are very small changes.
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Nerissa : then they're gonna have to get, like, this additional consent. They're gonna have to have a way to, like, put the user into
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Nerissa : I arguably, they can't be using it until using the app until they get consent, so they're gonna have to go into some type of, like, escrow or something until they get the consent. I don't know where what's gonna happen with these purchases until the kid can… like, if you're playing a video game and you want to purchase
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Nerissa : extra lives or something. The kid doesn't want to have to wait. And what are you going to do with the kid during that time period? There's a lot of operational issues. I think that there are probably
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Nerissa : And because of that, I think that these laws are really hard to comply with. I think that the California one has less operational issues, it's just so much broader that it's scary.
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Nerissa : That it's so much beyond the Apple and Google that it becomes scary.
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Priya Keshav: Let's talk about enforcement, right? FTC has been expanding its enforcement focus beyond traditional COPA compliance. How is that changing expectations, around collection of children's and deans' data, and broader accountability for the business as a whole?
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nmcginn: Yeah, the FTC, since they had that Fortnite decision, has really tried to, expand, to teens.
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Nerissa : And more recently.
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Nerissa : Yeah, so that was an expansion of, hey, we're not going to protect under the age of 13, but you've got to give some of those protections to teens, which was, I think, a wake-up call for a lot of people. But I think that the biggest thing that we're seeing now
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Nerissa : is really that the FTC is saying, like It's not just COPPA.
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Nerissa : It's any type of, like, what we deem as an unfair competition.
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Nerissa : type practice. So, what they've said is, we're gonna use, you know, their unfair competition, their Section 5 powers, we're gonna use our Section 5 powers to see, do we think that… is there any type of harm to kids?
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Nerissa : can we address that harm, and what's the cause of that what's the cause of that harm? Can we address the cause of that? And then, you know, can we address that cause through our Section 5 power? So it's kind of like.
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Nerissa : Blown up from some from an agency that's just looking at your advertising.
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Nerissa : And what you're telling the consumers to looking at your product, which is and how you're how you're creating that product, which is a lot broader and a lot scarier for a lot of these a lot of these companies.
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Priya Keshav: So we've also seen some cases and concerns from Texas, right? The Texas AG's lawsuit against Netflix, where they raised questions about the product design, where, you know.
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Priya Keshav: Netflix is collecting behavioral data, and also, children's profiles. What about the Netflix case, and how does it signal about where the regulators are headed, you know, in Texas and maybe other states as well, and why is that important?
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Nerissa : I think that the Texas… the Texas… the Netflix case, I think, should scare a lot of people, because it really is such an aggressive lawsuit, if you look at it. And they,
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Nerissa : I think that Netflix is not… it's not Facebook or a social media site, right? That it's it's a little it's different.
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Nerissa : arguably, and really, I think, a lot of the things that
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Nerissa : the Texas AG is concerned about is what we would call contextual advertising, right? So, we're not sharing that information with Colgate or some other brand or Ford. We're just using that information to say, hey, we know what you want to watch next.
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Nerissa : Right? And some of the examples were, like, if you tend to, like
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Nerissa : shows that have Black, actors, that then the person in the thumbnail that will come up would
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Nerissa : more likely be Black, right? Things like that.
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Nerissa : I don't think that a lot of people think of that as
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Nerissa : behavioral advertising as much as advertising within the within Netflix, right? And which is allowed under
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Nerissa : Right? And, you know, the that type of that type of advertising, that contextual advertising, is allowed under COPA, so this is a huge expansion.
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Nerissa : Of, of what we think of as the laws that are protecting of protecting children.
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Nerissa : And, you know, even I definitely some of the they tried to use some of their what they called they said that there were dark patterns that tried to
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Nerissa : show that,
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Nerissa : Netflix was addicting children to the use of Netflix. So, like, one of those features was the autoplay. So, like, when I'm done with episode 3, episode 4 starts playing right after that. I love that! I don't know about you.
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Priya Keshav: I don't have to click 3 more buttons to start the next episode, so it makes sense. Yes, I am.
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Priya Keshav: I agree, yes.
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Nerissa : I like being told, like, hey, we just saw you watched
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Nerissa : you know, some show on Netflix, and you might like these 5 shows, because then I know what I might like to watch next, right? And I like not having to go and press those extra 3 buttons, but they're kind of saying that those are addictive qualities.
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Nerissa : Or, you know, I guess, arguably, they'll say, hey, do you want to binge Bridgerton?
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Nerissa : Yeah, I want to binge Bridgerton, that's so bad!
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Nerissa : But they, they, you know, the Texas the Texas AG, is trying to address them. So, I mean, they're really trying to take any type of they're also trying to use their
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Nerissa : Unfair and deceptive practices, powers, against all of these against these,
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Nerissa : You know, any type of app or online service, which is a scary thing, because these are big lawsuits.
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Nerissa : And I think that a lot of people would have thought that what was going on really wasn't always all so bad.
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Priya Keshav: So, let's talk a little bit about New Mexico versus Metamatter. I think that also was, there it's a very important case, and there are some very important takeaways for
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Priya Keshav: companies designing products for minors. So, you know, maybe you want to tell us a little bit more about it, and why it's important.
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Nerissa : Yeah, so the New Mexico case is really it's again, it was not brought under a children's privacy law. It was not brought, you know, it was just brought under these
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Nerissa : unfair competition laws.
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Nerissa : And they, they are arguing that what Meta was doing is an unfair trade practice, and they got $375 million in damages in the Phase 1 of the trial.
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Nerissa : now we're going into the public nuisance part of the trial, which is Phase 2, which could be even more damages. We're kind of… we're waiting for the decision, in Phase 2. You know, I think the biggest thing for probably
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Nerissa : your clients, is that
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Nerissa : is it's really starting to look like Section 230 is not protecting the developers of, you know, app developers anymore. So, Section 230 is the law that pretty much, you know, says that
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Nerissa : You can't bring actions against an app developer for things that are posted on their website.
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Nerissa : Or for an online service provider, for things that are posted on their site. So, like, at a very basic level, it says that if I post something that is arguably illegal on Facebook.
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Nerissa : that, that is not Facebook's fault, right? And it, you know, Section 230 is arguably
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Nerissa : the it's called the law that created the internet. It gave these app developers the and websites and online services the ability to have, like, a safe harbor to be able to create their their sites.
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Nerissa : And now it looks like a lot of the functionality that was… that was, that Facebook created
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Nerissa : is not covered by Section 230 more. That Facebook argued it was, and they're and they're saying that
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Nerissa : at least the courts are saying that it the things that were challenged are not protected by Section 230. So, this is, you know, it could mean that there's a lot more lawsuits against these type… any type of online service provider, really.
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Nerissa : that, you know, the design of how they design their service is not going to be protected.
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Nerissa : And
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Priya Keshav: I'd be a yeah, go ahead.
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Nerissa : No, I It'll be a great
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Priya Keshav: Yeah, go ahead.
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Nerissa : The other thing that you kind of that I think we're seeing is that
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Nerissa : these types of websites that have kids on it, but say that, you know, say they're for over 13, but we kind of know that there are kids on it, they're gonna have to start doing more age verification. If it's not through the app stores, and these app store laws, they're gonna have to start doing it on their own.
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Nerissa : And that's what a lot of these settlements are, you know, that's one of the things that they're looking for in New Mexico.
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Nerissa : But there's been multiple settlements recently, one with Roblox, and then there was one recently with Roku that required more age verification. So I think that that's something that these that that websites and online services are going to have to look at.
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Priya Keshav: Yeah, I think that's something that, is going to be,
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Priya Keshav: it's not just, you know, you have products that are shared. Like, for example, I could be a subscriber, but, like, when it comes to Netflix, when it comes to Roku.
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Priya Keshav: you know, I may set up a profile, but I may not set up a profile, but what if kids watch it as well, right? So, it's looking at product development, you know, companies should start thinking about age verification and design, and I think you bring up a great point as to, you know, it's important for them to think about how they're going to do the age verification.
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Priya Keshav: But what does privacy by design look like in practice for these products, as they think about children
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Priya Keshav: And as they think about, you know, whether they're going to be accessed by minors, and especially mixed audience environments, where, you know, maybe the account holder is above 18, but that doesn't mean that the account holder is the only user for that service.
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Nerissa : Yeah, I think that
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Nerissa : you are going to have to, first of all, I think privacy by design now is it's not there's not going to be a distinction as much between children and minors, right? That the under 13, under 18 is going to start to disappear.
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Nerissa : And you're just gonna treat everyone as under 18. I think a great example of that right now is Gemini, Google Gemini. If you look at Google Gemini.
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Nerissa : they, to have a Gemini account.
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Nerissa : You have to be 18.
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Nerissa : for, you know, the general account. Like, so, you know, they're they're definitely and I think that that's something that, that companies are going to have to to look at. They're gonna have to look at, like, what age do I really want my product to be addressed
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Nerissa : like, to be designed for, and if it's if it's 18 and up, what am I gonna do with those people, those users that are under 18?
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Nerissa : Right? Like, am I gonna have a separate product, or a separate way for these users to access my service?
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Nerissa : And so that's that's gonna be, I think, a really big step that people are going to have to take, because they're gonna know
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Nerissa : Now, and there's gonna have to be these additional protections for the under 18, so how are we… how are we gonna silo the under-18? And what are we gonna do with…
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Nerissa : Because they might not be able to do everything that that they want to do under, you know, in my service. Or I'm not going to be able to collect information the way I want to from those users.
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Nerissa : And how do we treat them differently?
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Priya Keshav: So what should privacy, legal, and product teams be watching for more closely over the next 12 to 18 months?
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Nerissa : I think the first thing that I would look at if I was
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Nerissa : you know, if I was, you know, privacy legalist, first of all, I think I would kind of, like, do
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Nerissa : an analysis of to the extent that I know, who are my users? Like, are what age groups are my users are my users in? And you're going to have to decide
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Nerissa : you know, what are you gonna do with your privacy policy, and what are you gonna do with your age rating in the App Store? There was just a recent case
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Nerissa : That was filed by the Florida AG against TikTok, where they said that their app store, the age rating in the app store, was part of was one of the things that was an unfair that was, like, a deceptive practice.
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Nerissa : Has and so, like, you're gonna have to look at making sure that
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Nerissa : You know, if you say that you're
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Nerissa : 18 in your privacy 18 up in your privacy policy, what is it saying for the App Store?
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Nerissa : And does that match? Do you want it to match? Things like that, right? And…
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Nerissa : then I think you're, you know, you're gonna have to think about, in the future, that, especially in the next 12 to 18 months, like, what are we gonna how are we gonna silo these users, and what are we gonna do with them?
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Nerissa : That are under 18.
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Nerissa : You know, are we going to have like, I don't know that you're gonna be able to have, like, a YouTube Kids as compared to YouTube for everybody, right?
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Priya Keshav: Yeah, it's a big question, right? Whether I'm gonna provide the same kind of
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Priya Keshav: benefits, safeguards in the regular app, or am I going to segregate the kids' app into something different? That's a… that's a big question to ask.
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Nerissa : Yeah, I think it I think that is a it's gonna be a big question, and I don't think that everybody is going to be able to create a second app for the kids. It's just… it's too burdensome, it's too much money, right? So then how are we gonna…
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Nerissa : how are we going to make sure that those users, like, that we're not collecting information from the users that are under 18? Or if they can't go to certain areas of the site, how are we going to enforce that? And and, you know, what walls do we have to put up?
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Nerissa : And, both internally and for that user.
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Priya Keshav: So, Narissa, thank you so much for joining us today and for helping us unpack such complex and, you know.
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Priya Keshav: fast-moving
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Priya Keshav: regulations in this area. What stands out from our conversation is that the children's privacy is no longer just a compliance checkbox, or a privacy policy update, or a narrow COPA issue, but a broader accountability issue that touches product design, data governance, advertising practices, parental control, online safety, and how the platform…
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Priya Keshav: How, you know, products or apps interact with various platforms or app stores.
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Priya Keshav: For companies, the practical takeaway is clear, not to wait for a perfect regulatory consistency, which is probably not coming. There's not going to be a centralized one standard for everyone. Organizations and businesses should start considering where minors and teens will interact with their products. Age verification looks like should be a must.
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Priya Keshav: And, and they have to understand what kind of data is collected.
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Priya Keshav: How consent will be applied, and, you know, how the product is going to change and interact with the minors and teens, especially with respect to parental controls and other design changes, you know, based on,
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Priya Keshav: based on how many teen and minors are using the app.
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Priya Keshav: I feel the companies that are better positioned to treat children's privacy, you know, ahead of what's coming, and more as a cross-functional issue, are probably in a better position to sort of be compliant. But, do you have any other closing thoughts? Anything that we have not discussed, or that you want to bring up, before we sort of
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Nerissa : I think that, at this point, it's just, you know.
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Nerissa : making sure that you know what laws are out there, and starting to get prepared, especially if you think that you have users that are under the age of 18. And I just don't know, there are very few companies out there that,
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nmcginn: That probably
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Nerissa : You know, unless they're, you know, like, business enterprise-type companies that don't have users under 18.
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Nerissa : Right? I mean, you still even have even sometimes, like, if you have, like, a retail store, they're gonna have like, if they have users that, within the store, that are using their app for the employees, they probably have employees that are under 18, and how are you gonna deal?
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Nerissa : with those users to make sure that they can even download your app and use it.
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Priya Keshav: No, agreed. Yeah, I think, I think, especially
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Priya Keshav: Yeah, very few I think a mixed and shared audience, you know, when you start considering those, the number of companies that have teen and minor users, you know, a number of them exist. So far, most of them have just probably just updated their privacy policy to say we serve people above 18, and so they need to re-look at how they're handling
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Priya Keshav: Children's data.
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Nerissa : Yeah, I agree.
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Nerissa : I agree.
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Nerissa : Well, thank you so much.
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Priya Keshav: Yeah, to our listeners, thank you for joining us on Simplifying for Success. Hope today's discussion gave you a very a clearer view of the evolving children's data landscape and practical steps to consider as you strengthen your privacy and governance programs. Thank you, Nerissa, for joining us. We look forward to having you join us in future episodes, and for our listeners, you know, we look forward to you
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Priya Keshav: continuing to listen to our podcast. Thanks.