Coalition Comments to the FTC on Children’s Online Privacy Protection Rule
Children’s Privacy Advocates generally support the Commission’s revised proposals, including the Commission’s proposed definition of “personal information” to include persistent identifiers used for functions other than or in addition to support for the internal operations of the website or online service. However, we oppose the proposed change in the definition of “directed to children,” because it would undercut the other beneficial proposals and lessen privacy protections for children. We also do not support the newly revised proposal to redefine “support for internal operations,” because the newly proposed definition would create a large loophole that could allow operators to engage in behavioral advertising to children.
