Question

Kids - English Learning Apps

  • 24 January 2020
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We have a kids - english learning app and have integrated Mixpanel on it. When we submitted our App to IOS store, it got rejected. 

 

So is there any way to get it approved. Or do I have to remove Mixpanel altogether. There should be proper guidelines for this. 

 


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@arif  —

You do not need to remove Mixpanel to get your app accepted. As a data analytics company, Mixpanel is exempt from COPPA's requirements that a party with a "child-directed" website or app obtain parental consent when receiving information from children.
 

If you'll take a look here: (http://www.gpo.gov/fdsys/pkg/FR-2013-01-17/pdf/2012-31341.pdf), you'll notice that in 2013 the US Federal Trade Commission - the governing body that enforces COPPA - amended the rules so that web analytics vendors fall under "support for internal operations" exception. In essences this means that we're exempt from the notice and consent requirements of COPPA.
 

There's also a great summary here on the FTCs guidance on the issue: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Exceptions
 

In addition, your team is more than welcome to take a look at our terms of service: https://mixpanel.com/terms. In the eyes of Mixpanel, you own the data you send to us. The only people who will have access to your data are you or your team and anyone you invite to the project. We take data security very seriously, and Mixpanel can guarantee that no data will be used for advertising or shared with any 3rd party services and if upon request, your data will be deleted. Lastly, if you are still worried about any of this you can always choose to not send us any PII of your customers at all and instead hash encode everything so no one will ever have data on specific individuals.

 

Here is some additional context:

  1. Use of Mixpanel Complies with COPPA.  Companies can use third-party analytics internally and the third-party analytics companies do not have to separately obtain parental consent. Therefore, where the potential company collects persistent identifier information from users of its child-directed site and uses a third-party site like Mixpanel to perform analytics encompassed by the COPPA's “support for internal operations” definition, and the information is not used for any other purposes not covered by the support for internal operations definition, then you can rely upon COPPA's exemption from parental and consent. 
  2. Right to Process Information for Children Under 13.  Mixpanel's right to process information collected from children under 13 flows from our customer's compliance with COPPA. Thus, as mentioned above, Mixpanel's compliance is dependent upon our customers' proper compliance with COPPA and Mixpanel works with its customers to ensure proper processing. 
  3. First Party Analytics.  Mixpanel can be configured to collect information directly from an internal, proxy server in a fashion compliant with Apple's definition of first party analytics.  Under this process, Mixpanel's SDK are configured to direct information to the customer's proxy server, not api.mixpanel.com.  That server then uses Mixpanel's ingestion API to send data to Mixpanel for processing.  
  4. Mixpanel Does Not Sell Information.  No part of Mixpanel's business is based on selling data to third parties, like advertisers.  The information you share with Mixpanel is stored within Mixpanel for the customer's use; not for ad serving, ad targeting, or the like. 

@cherise 

So we can share the above guidelines that you shared to IOS store support team? 

Userlevel 5
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@arif — sure! 

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