Penalty Amount
$500,000
Tilting Point Media LLC illegally collected and shared children's personal data in its mobile app game 'SpongeBob: Krusty Cook-Off' without parental consent, violating COPPA and CCPA. The settlement imposes a $500,000 civil penalty and injunctive terms to ensure compliance with children's data privacy laws.
Tilting Point must pay $500,000 in civil penalties, comply with CCPA and COPPA by obtaining parental consent for children's data, use neutral age screens, properly configure third-party SDKs, implement an SDK governance framework, minimize data collection from children, and submit annual compliance reports to the California Department of Justice and Los Angeles City Attorney's Office.
In-house legal teams should review all vendor agreements with mobile app developers, third-party SDK providers, and advertising technology vendors to ensure alignment with COPPA and CCPA children’s data requirements. Key clauses to audit include data processing agreements (DPAs) to verify parental consent is obtained prior to collecting or sharing children’s personal information, SDK configuration terms to mandate proper setup of third-party tools to prevent unauthorized data collection, and age-gating provisions to require neutral, non-manipulative age screens. Customer-facing agreements for children-directed games should include clauses requiring opt-in consent for users aged 13-16 and just-in-time notices detailing data collection practices. Additionally, all relevant agreements should incorporate compliance monitoring, reporting obligations, and breach notification clauses consistent with applicable privacy laws.
Entity
Tilting Point Media LLC
Also known as: Tilting Point Media
Industry
GamingOfficial Press Release
https://oag.ca.gov/news/press-releases/attorney-general-bonta-la-city-attorney-feldstein-soto-announce-500000
Complaint People v Tilting Point Media LLC (filed)
https://oag.ca.gov/system/files/attachments/press-docs/Complaint%20People%20v%20Tilting%20Point%20Media%20LLC%20%28filed%29.pdf
Tilting Point Final Judgment (7 2 24)
https://oag.ca.gov/system/files/attachments/press-docs/Tilting%20Point%20Final%20Judgment%20%287-2-24%29.pdf
California Attorney General Enforcement Page
https://oag.ca.gov/privacy/privacy-enforcement-actions
"Tilting Point Media LLC (Tilting Point)"
"$500,000 in civil penalties"
"violated the California Consumer Privacy Act (CCPA) and the federal Children’s Online Privacy Protection Act (COPPA)"
"collecting and sharing children’s data without parental consent"
"California Attorney General Rob Bonta"
"comply with strong injunctive terms ensuring legal data collection and disclosure, including obtaining parental consent and diligence in configuring third-party software in their mobile games"
$500K
California Attorney General Rob Bonta and Los Angeles City Attorney Hydee Feldstein Soto announced a $500,000 settlement with Tilting Point Media LLC over allegations that the company violated COPPA and the CCPA by illegally collecting and sharing children’s personal data without parental consent via its 'SpongeBob: Krusty Cook-Off' mobile game. The settlement requires Tilting Point to pay $500,000 in civil penalties and comply with injunctive terms including implementing neutral age screens, obtaining parental consent for children’s data collection/sharing, and maintaining an SDK governance framework. Tilting Point must also submit annual compliance reports to the California DOJ and LA City Attorney’s Office.
Governor Newsom signed the Expanding Privacy Rights Act (SB 923), expanding CCPA deletion rights to cover personal information obtained from third parties and requiring online-only businesses to offer an online method for submitting privacy requests. The law takes effect January 1, 2027, and allows businesses to maintain suppression lists to help keep deleted information from being reacquired.
The California Privacy Protection Agency announced that the California State Legislature approved the Expanding Privacy Rights Act (SB 923), which expands the CCPA's right to delete to cover all non-exempt personal information a business holds about a consumer, including data originally collected from third parties. The bill also requires online-only businesses with a direct relationship to consumers to provide online methods, such as webforms, for submitting access, deletion, and correction requests, and expressly permits businesses to retain suppression lists so deleted information stays deleted. The bill, authored by Senator Becker and sponsored by CalPrivacy, now goes to the Governor for consideration.
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