New: a trial court in 1 of every 10 U.S. counties. Read the post
Court Rules
All enforcement actions
Consent DecreeHigh Risk

FTC Settles Kuuhuub Over $3M COPPA Violation

Kuuhuub Inc.July 1, 2021Federal Trade Commission

Penalty Amount

$3,000,000

Summary

The FTC settled with Kuuhuub Inc., operator of the Recolor coloring book app, for violating COPPA by collecting personal information from children under 13 without parental consent. The app's social media features allowed children to register and share data, and third-party ad networks collected persistent identifiers for targeted ads. The settlement requires deletion of children's data, refunds to underage subscribers, a $3 million penalty (suspended upon $100,000 payment), and user notifications about the violations.

Remedy

The companies must delete all personal information collected from children under 13 unless parental consent is obtained, offer refunds to current paid subscribers who were under 18 at sign-up, pay a $3 million monetary penalty (suspended upon payment of $100,000), and notify app users about the COPPA violations and steps to take.

Monetary PenaltyData DeletionConsumer RefundsCorrective Notice

Contract Impact

In-house legal teams should review all agreements involving the Recolor app or similar child-directed services, including vendor contracts with third-party ad networks, customer-facing terms of service and privacy policies, and any data processing agreements. Focus on clauses governing data collection from minors, consent mechanisms (especially verifiable parental consent), third-party data sharing and advertising integrations, data retention and deletion policies, and age-screening procedures. Updates may be needed to ensure robust parental consent workflows, restrict collection of personal information from users under 13, audit and restrict third-party ad network data practices, implement clear children's privacy notices, and establish automatic data deletion protocols for underage users to comply with COPPA.

Contract Search Terms

verifiable parental consentchildren's data collection clausethird-party data sharing agreementad network SDK integrationage-screening mechanismdata retention policy for minorsCOPPA compliance addendumparental consent formchildren's privacy noticedata deletion upon request

Laws Cited

Violation Types

Entity Details

Entity

Kuuhuub Inc.

Also known as: Kuuhuub

Industry

Technology

Official Sources

Source Evidence

Entity Name
"Kuuhuub Inc."
Fine Amount
"$3 million monetary penalty"
Laws Cited
"Children’s Online Privacy Protection Act Rule (COPPA Rule)"
Violation Types
"collecting personal information from children under the age of 13"
Violation Types
"failed to provide notice to parents"
Violation Types
"failed to obtain verifiable parental consent"

Related Enforcement Actions

FTC

REPS & Company Inc.

The FTC referred a complaint against REPS & Company Inc. and company executives, alleging they bypassed ticket-issuer security controls and purchasing limits to acquire millions of tickets for resale. The complaint was filed by the Department of Justice, and the case will be decided by the court; the press release does not report a penalty or other remedy imposed.

FTC

Digital Forensics Corporation LLC

The FTC sued Digital Forensics Corporation LLC and affiliated defendants, alleging they misled sextortion victims with promises of investigative and monitoring services that often were not provided, and used fake positive reviews. A federal court granted the FTC’s request to temporarily halt the defendants’ activities; the complaint remains for the court to decide.

FTC

Greenway Auto Group

The FTC alleged that Greenway Auto Group advertised vehicle prices thousands of dollars below the amounts consumers actually paid and used mailers falsely suggesting recipients had won cash prizes. Greenway agreed to an order requiring transparent pricing and prohibiting deceptive prize mailers and other misrepresentations; the press release does not state a monetary penalty.

FTC

24 healthcare services companies (not individually named)

The FTC sent warning letters to 24 large healthcare services companies, cautioning that incomplete, inaccurate, or untimely pricing information for scheduled medical care may be unfair or deceptive. The letters urge recipients to review their price-disclosure practices and take corrective action; they announce no fine or formal order.

FTC

Premier Franchising Group LLC and Franchise Fastlane LLC

$1.9M

The FTC alleged that Premier Franchising Group LLC and Franchise Fastlane LLC made deceptive and unsubstantiated claims about the Premier Martial Arts franchise opportunity and violated the Franchise Rule. The proposed settlements require the companies to pay a combined $1.85 million to compensate franchisees, prohibit certain misrepresentations, and require Franchise Rule compliance; certain franchisees may also cancel their agreements without penalty.

FTC

Lens.com Inc.

The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.