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you must comply with section 5 of the ftc act. section 5 requires that operators of child-directed websites or services "not use deceptive practices in connection with children's websites or services. the rule defines deceptive practices as those "that have the purpose or effect of.. [making] children or their parents more likely to provide personal information or more likely to provide personal information of children to the operators of child-directed websites or services." see also pp. 5-6, above. for example, if you provide online surveys, you must take steps to make sure that they are not deceptive.


the survey bypass means that you can collect personal information for surveys on child-directed sites or services, but you must comply with coppa. you can do this by posting your privacy policy on your site or service. it should be visible to visitors to the site or service, in its own section, and prominently displayed on the homepage.


in addition to the posted privacy policy, you must also include a direct notice to parents and obtain verifiable consent for online surveys. this verifiable consent must be "clear and conspicuous," "immediately available" to visitors, and be "accessible in a way that does not interfere with the child-directed experience or the operation of the website or service." the linked notice must be provided either before the visitor enters the site or service, or immediately after entering the site or service and before the visitor is required to provide any personal information. the notice must be provided in a format that is easy to understand. in addition, the notice must be "clearly and conspicuously" visible and include the name and telephone number of a contact person, as well as a mechanism for the visitor to contact that person. finally, the notice must be provided in an online format that is readily available to visitors. the text of the notice may be provided in the following ways: 84d34552a1