In September 2015, the Online Interest-based Advertising Accountability Program (Accountability Program) of the Advertising Self-regulatory Council (ASRC) began enforcing the Digital Advertising Alliance (DAA) Guidelines for Mobile Advertising (Mobile Guidance) and now the inevitable has happened: the Accountability Program has issued three compliance decisions with mobile app publishers whose apps allegedly failed to comply with the Mobile Guidance. Two of those decisions, the Bearbit Studios decision and the Top Free Games decision, reinforce the heightened duties that mobile app publishers take on when developing mobile apps that appeal to children under 13 (children). For more information on the third decision, the Spinrilla decision, and the Accountability Program’s stance on cross-app enhanced notice and precise location data, see our companion post here.
