Legal Compliance for Mobile Apps

Children's information and sharing it is top of mind for regulators, as we have been telling our clients for a while, and as we saw yesterday in a new CA AG $500,000 settlement with Tilting Point Media LLC (Tilting Point) for #CCPA and #COPPA compliance issues in mobile app game “SpongeBob: Krusty Cook-Off.” Practice points: Directed at children: 🔹 If you are aware that children under 13 are using your services - they are is directed to children. Saying in your terms of service and privacy policy that consumers under 13 are not authorized to use it - doesn't change this. Regulator 1, 2, 3: 🔹 CA AG will use every enforcement tool to ensure compliance with the law and that companies exercise diligence with privacy law requirements 🔹 If one regulator tells you that you are not compliant (here BBB National Programs CARU): assess your compliance with other laws you could be enforced against by another regulator Data minimization: 🔹 Don't collect more personal information than reasonably necessary for a child to participate. Mind your SDKs: 🔹An SDK facilitates data sharing that can be a sale (CCPA) and/or unfair/deceptive (FTC) and/or subject to COPPA just like any data sharing. 🔹 You need to know: what information each SDK collects; evaluate contracts re: sharing of data through them - making sure you have the right consent. 🔹 You may need a formal SDK governance framework. 🔹 Every year: assess data minimization and SDK usage. (ensuring data flows appropriately change based on the consumer's age). 🔹 Every year: conduct adequate training for personnel re sharing and SDKs Sale/share: 🔹 Disclose your sale and share correctly in your privacy notice 🔹 Don't sell/share personal information of under 13's without parental consent 🔹When you do sell/share: provide a just-in-time notice explaining what information is collected, the purpose, sale/share, link to privacy policy, & parental or opt-in consent required. [FTC also says this in BetterHelp] Mixed audience 🔹When using an age screen it has to be neutral. 🔹Neutral means: (1) ask age information in a neutral manner that does not default to a set age of 16 or above or encourage users to falsify age information; (2) not suggest that certain features will not be available; and (3) provide CLEAR AND CONSPICUOUS notice that the age entered should be accurate to the user and is collected to ensure data use and advertising is appropriate. 🔹If the person is under 13 or 16 - direct them to a portion of the service that doesn't use data other than as permitted by COPPA/CCPA or get parental / opt in consent For ads in your apps, make sure they are: 🔹Identified as being an ad; 🔹Include a prominent one-click “X” or “Close” button; 🔹Do not manipulate or deceive consumers into engaging 🔹Do not advertise activities/products in which children cannot legally engage/possess. #dataprivacy #dataprotection #privacyFOMO Complaint: https://rb.gy/enu19e Agreement: https://rb.gy/jq6lke

Last week Utah's governor signed a new law on mobile apps and age verification. Here's three things all companies with mobile apps should to do to prepare ⤵️ #Utah's App Store Accountability Act law will result in app stores telling all companies with mobile apps which specific users are children or minors, on or before May 6, 2026. This is for all mobile apps--even ones that aren't intended for children or minors. Companies that distribute apps via app stores will have a number of obligations under the law, including to: 🔸Get age data using the app-store designated method to determine the age category of each app user, and if corresponding to a minor, confirm that verifiable parental consent has been obtained. Age verification data or parental consent also needs to be collected when users download or purchase an app, the developer makes a "significant change" to the app, or as needed to comply with applicable law. 🔸Act on age data, including by enforcing any age-related restrictions, complying with applicable laws, and implementing any safety features or defaults. 🔸Notify app stores of "significant changes" to the app including changes to terms of service or privacy policies that change categories of data processed, alter age ratings or content descriptions, add new monetization features (purchases or ads), or materially change functionality or user experience.   Companies with mobile apps won't be able to enforce contracts or terms of service against minors unless they confirm (via the app store method) that verifiable parental consent was obtained. If age information on file with the company differs from age information provided by the app store, the lowest age needs to be used. The law includes a private right of action, with statutory damages of $1,000 per violation (or actual damages, whichever is higher).   The law creates new #compliance obligations for all companies with mobile apps, including under the federal Children's Online Privacy Protection Act (COPPA) and under other state #privacy laws that treat data of certain minors as "sensitive personal data." In the months ahead, if your organization has any mobile apps, plan to:   1️⃣Confirm there are processes for addressing COPPA and other applicable children's privacy requirements when your organization learns a specific user is a child or minor; 2️⃣Plan for how these processes can be leveraged when you learn from app stores that particular users are children; and 3️⃣Work with your #MobileApp team to start to plan for the other requirements in the law, and to monitor for app store developer updates relating to the sharing of age data. The Act is at https://lnkd.in/gK9-MZn9 #ios #android #dataprotection

As the Chief Product Explainer for Google Play policy, I know keeping up with policy updates can feel like a full-time job. But every change is rooted in our commitment to user trust and helping you build a better business. So far, 2025 has brought important shifts. Here's my breakdown of the most significant updates and why they matter to your roadmap: User Safety & Transparency: Photo & Video Permissions (May): This is a huge privacy win. It restricts access to only what's directly required for your app's core function. Your Action: Audit your manifest and ensure you are requesting only the minimum necessary media access. Health Connect Policy (March): Strengthens safeguards for extremely sensitive health data. Your Action: Review the stricter eligibility criteria if your app accesses medical history or lab results. Medical Functionalities (May): Ensures apps providing health info are reliable and safe by incorporating the latest medical guidance and clear disclaimer requirements. News & Magazines (August): Expanded to include magazine apps and a broader self-declaration process. Your Action: If you distribute content, complete the updated declaration in the Play Console for credibility standards. Personal Loans Policy (Updated): Clarified to include line of credit apps and specify limited regional exceptions (like Pakistan), protecting users from financial fraud. Technical Readiness & Performance: Target API Level (August 31): New apps and updates must target Android 15 (API level 35) or higher. The Why: This ensures your app runs securely and performantly, leveraging the latest platform features. Extension available until Nov 1, 2025. Play Billing Library (August 31): Update to version 7 or newer for improved transaction security and a consistent purchase experience. Extension available until Nov 1, 2025. 16 KB Page Size Compatibility (Nov 1): A key technical update for performance. Apps targeting Android 15+ must support 16 KB page sizes to be more efficient on newer devices. Your Action: Check your native code dependencies and use the latest tooling. My goal is to make compliance feel less intimidating. Use these deadlines to prioritize your development schedule and always use the official Google Play Developer Policy Center as your source of truth: https://lnkd.in/gzgkaq7g Which of these updates is currently highest on your team's priority list? Let me know in the comments. #GooglePlay #PolicyUpdate #AndroidDev #DeveloperExperience #ChiefProductExplainer

Does your company's app have a working opt-out of selling/sharing mechanism? If not, and your company is subject to the #CCPA and sells personal information or shares it for cross-context behavioral advertising, your company should implement a compliant mechanism as soon as possible. A recent CCPA enforcement action against a mobile game developer stresses the importance of getting compliance right in the mobile app context. The California AG just announced a $1.4 million settlement to resolve claims that the defendant failed to offer players of its popular mobile games a mechanism to opt out of the selling and sharing of their personal information for cross-context behavioral advertising. The AG also claimed that the defendant misconfigured its games' age gates, and failed to obtain opt-in consent to sell and share children's personal information, as required by law. Selling/sharing in the mobile context often happens as a result of SDK integrations and incorporating AdTech APIs. Additional requirements apply if you're selling/sharing sensitive data (e.g., health, precise geolocation, and children's data). Publicly reported CCPA enforcement actions have largely focused on websites, but this case demonstrates that mobile apps are on regulators' radars too. And the recent amendments to the CCPA regulations (many of which take effect on Jan 1, 2026) show that regulators are thinking about other types of online platforms, including virtual, mixed, and augmented reality devices. Whatever the user interface, double-check your compliance, because California privacy regulators are active.

𝐔𝐛𝐞𝐫 𝐀𝐈 𝐄𝐧𝐠𝐢𝐧𝐞𝐞𝐫 𝐈𝐧𝐭𝐞𝐫𝐯𝐢𝐞𝐰 𝐐𝐮𝐞𝐬𝐭𝐢𝐨𝐧 Your AI product runs in 30 countries. Each one has its own privacy and data-protection laws — GDPR in the EU, India's DPDP Act, CCPA in California, and dozens more. They contradict each other. Some demand data stays in-country. Some grant a "right to be forgotten." Some restrict what you can even send to an LLM. How do you design one system that complies with all of them? 👇 1. Data residency by region. Don't run one global database. Partition storage by region (EU data stays in EU). Route requests to the regional stack based on the user's jurisdiction — not where your servers happen to be. 2. Policy as configuration, not code. Encode each country's rules (retention period, consent requirements, allowed processing) as a policy engine the app reads at runtime. Adding a new country = new config, not a rewrite. 3. Consent + purpose tracking at the data layer. Tag every record with its legal basis and purpose. Before any processing (training, LLM calls, analytics), check the tag. No consent → no processing. 4. Minimize and redact before the model. PII detection + redaction before prompts reach the LLM. The less personal data that leaves the region, the smaller your compliance surface. 5. Build for deletion and audit from day one. "Right to be forgotten" must cascade through caches, embeddings, logs, and backups. Keep an immutable audit trail proving what you did and when. ======================================== I’ve covered questions like these in my AI Engineering Interview Master Bundle, a comprehensive set of 22 courses designed for real interview prep. Explore the full guide here → https://lnkd.in/gqFkWZd4

California is at the forefront again! The Digital Age Assurance Act (AB 1043) was signed into law by the Governor on October 13th and will become effective January 1, 2027. This law creates a standardized system for verifying user age through operating systems - APP DEVELOPERS BEWARE - you'll need to pull information from the OS to comply! 🗝️ Key Requirements: Operating Systems (OS providers): ❓ Must ask the account holder for the user’s birth date or age at device setup. ➡️ Must transmit an age bracket signal (not the actual age) to apps via a secure, real-time API. 🟰 Must apply the same obligations to their own apps as to third-party apps. Age Brackets: 👼 Under 13 🐣 13–15 🐥 16–17 🐔 18 and older Developers: 🙏 Must request an age signal when an app is downloaded or launched. 🧠 Are deemed to know the user’s age range once the signal is received. 🚫 May not collect or share extra data beyond what’s needed for compliance. Deadlines: Jan. 1, 2027: Law becomes operative. By July 1, 2027: OS providers must update older devices; developers must request age signals for existing users. Enforcement: Attorney General only. Civil penalties: 💲 Up to $2,500 per child (negligent) 💰 Up to $7,500 per child (intentional) Safe harbor for good-faith compliance. https://lnkd.in/gbu3iJhr #ageassurance #agegating #childrensprivacy #privacy #privacylaw #californiaprivacy #iketanilaw #attorneygeneral #enforcement #dataprivacy #appdevelopers #operatingsystem #goodfaith #agesignal #digitalprivacy #calag #ccpa

Epic Games paid $245 Million...But one bad UI decision? That’s all it took. And most fintech founders still think compliance is a legal team problem. It’s not. It’s a product design problem. I’ve seen fintech apps spend months perfecting dashboards, onboarding flows, and AI experiences… Then get exposed by one tiny interface detail. A misleading button. A hidden warning. A confusing consent flow. And suddenly, the UI becomes legal evidence. Epic Games paid $245M because users were pushed into actions they didn’t fully understand. WhatsApp paid €225M because regulators believed users clicked “Agree” without real clarity. Read that again. Here’s where most products are dangerously exposed: Your “Accept” button is brighter than “Decline.” That’s now considered a dark pattern. Your risk warnings are buried in grey text. But your CTA is glowing green. Your error states confuse stressed users. Your urgency timers pressure decisions. These are no longer “UX mistakes.” They are compliance risks. And regulators are watching closely. Especially in fintech, where one screenshot can trigger an investigation. The scary part? Most founders optimize for conversion. Regulators optimize for informed consent. Completely different game. At Design Monks, we design fintech systems that balance growth with regulatory trust. Because modern fintech UI is no longer just about looking premium. It needs to survive audits too. Comment “AUDIT” and I’ll show you where your fintech product may already be exposed.

The Supreme Court has responded, allowing Texas to enforce its App Store Accountability Act while legal challenges play out in the courts. After being initially blocked by a federal district court, the Fifth Circuit reinstated the law last month and the Supreme Court has declined to intervene. The law requires Apple and Google to verify the age of app store users but also creates obligations for mobile app developers. If you have a mobile app that is available to Texas users, this decision is notable for a few reasons: 🟣 The law is broad in scope and requires any mobile app developer to assign an age rating to their application, with a description justifying the age rating ⚪ Developers must use the age category transmitted by the app store to ensure that restricted content and transactions are not accessible to users without proper consent and controls 🔵 Because the First Amendment challenge is still pending, the law's enforceability remains uncertain. Companies should be prepared to adjust their compliance posture depending on how the Fifth Circuit rules. Stay tuned as I continue to monitor the developments in this space. https://lnkd.in/gzMcUW2u