CARU Recommends Kano Computing Modify Privacy Practices, Sweepstakes Promotion

New York, NY – Oct. 10, 2018  – The Children’s Advertising Review Unit (CARU) has recommended that Kano Computing, Ltd., operator of the Kano.me website, modify its privacy practices to bring them into compliance with the Self-Regulatory Program for Children’s Advertising, including CARU’s guidelines on privacy, and the federal Children’s Online Privacy Protection Act (COPPA). The company has agreed to do so.

CARU, an investigative unit of the advertising industry’s system of self-regulation, monitors advertising directed to children in all media and across all platforms. CARU monitors websites and digital platforms for compliance with CARU’s guidelines and with COPPA. CARU is administered by the Council of Better Business Bureaus.

The website came to the attention of CARU through CARU’s ongoing monitoring.

Kano products are step-by-step toolkits that teach users how to program and code their own computers. Kano offers at its website a variety of products that aim to help people “understand technology and create with code.” The most comprehensive product, the Computer Kit Complete, includes a real computer, powered by Raspberry Pi 3 and Kano OS.

The site allows registered users to create profiles, share creations, view and comment on posts from other registered users.

Language at the site states that it offers registered users: “A place to connect, share creations publicly and with friends, get inspired by other users, share feedback on other users’ creations and find out about Kano news and updates.”

CARU determined upon initial review that the registration process required children to share a first name, username and password.  Although children were directed to find an adult to help them register, children were also able to register by supplying a “parental” email address and accepting the terms and conditions.

Once registered, children could create a profile, share creations, message users privately and comment on other users’ creations publicly where they could freely enter text.

CARU noted that the website did not attempt to obtain verifiable parental consent or send direct notice to the email address collected during registration. Further, CARU noted there was no Federal Trade Commission-approved method for securing parental consent before the collection or disclosure of children’s personal information.

CARU also was concerned that the website collected or allowed third parties to collect persistent identifiers, or other personally identifiable information, that could be used to recognize a user over time and across different websites.

Finally, CARU questioned whether the odds of winning a sweepstakes advertised at the site were clearly disclosed as required by CARU’s guidelines.

Following its review, CARU recommended that the operator implement an FTC-approved method for obtaining verifiable parental consent. Kano informed CARU that it is currently working with legal counsel to implement more stringent rules to comply with COPPA and the General Data Protection Regulation.

At the time of CARU’s review, Kano’s privacy policy stated the following:

“We sometimes advertise on third-party websites, and we may allow our trusted advertising partners to place targeting cookies so that we can provide more interesting content.”

The use of cookies for behavioral advertising requires an operator to obtain verifiable parental consent. In its response to CARU, Kano stated that its privacy policy inaccurately reflected the actual practices.

Because there was tracking on the homepage http://kano.me, CARU recommended that the site refrain from utilizing tracking on the site without obtaining verifiable parental consent in the future. CARU also recommended that the Kano continue to update its privacy policy to reflect its actual privacy practices.

CARU also recommended that future sweepstakes advertising provide the requisite disclosures in conspicuous form at the point of entry.

Kano, in its advertiser’s statement, said the company “accepts CARU’s decision and is implementing changes raised by CARU with immediate effect. Kano thanks CARU for its efforts in this process, as it takes these matters seriously and is constantly working to improve all communications with our customers and users, operating to the highest possible standards.”