According to the complaint, the operators received numerous complaints from parents concerned with their children’s use of the app’s social media features to interact with adult users. The FTC alleged that some children, including those under 13, were able to register for an account with the app and use the app’s social media features. In its complaint, the FTC alleged that, while the app was billed as a “coloring book for adults,” a portion of the app was directed to children, therefore making the app subject to COPPA. To access the social media features, users must register for an account by providing an email address, screen name and optional profile description and picture. The Recolor app provides images that users can digitally color on their mobile devices and social media features that allow users to upload images for others to view, comment on, and like. The FTC alleged that the app operators violated the COPPA Rule by collecting and disclosing personal information from child users of the app without first notifying their parents or obtaining verifiable parental consent. and its Finnish subsidiaries Kuu Hubb Oy and Recolor Oy, operators of the online coloring book app, Recolor. On July 1, 2021, the Federal Trade Commission settled a complaint brought under the Children’s Online Privacy Protection Act (“COPPA”) against Toronto-based Kuuhuub Inc.
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