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[TikiTina]

Hi.  I'm usually a lurker, but I came across something really worrying, and I figured this forum was a good place to bring it up, since there seem to be a lot of parents here. 

CARU is a watchdog group affiliated with the BBB which covers media that's directed at kids.  Apparently some time over the summer, they conducted a review of VFK and didn't like what they saw.  I guess the powers that be at VFK didn't cooperate with CARU, and now they're being referred to the FTC.

CARU REFERS VIRTUAL FAMILY KINGDOM TO FTC AFTER COMPANY DECLINES TO SUBMIT RESPONSE TO INQUIRY

Basically, CARU found that VFK was not COPPA compliant and that it didn't follow through on promises that were on its web pages at the time of review.  The press release is pretty sparse, but this is not a good sign for this game.  Anyway, I was pretty shocked even though VFK isn't all that big at my house - we're more build-a-bearville people these days, lol.  But I thought that anyone with kids in the game at least deserved to know.

[KingQuackATac]

Hi.  I'm usually a lurker, but I came across something really worrying, and I figured this forum was a good place to bring it up, since there seem to be a lot of parents here. 

CARU is a watchdog group affiliated with the BBB which covers media that's directed at kids.  Apparently some time over the summer, they conducted a review of VFK and didn't like what they saw.  I guess the powers that be at VFK didn't cooperate with CARU, and now they're being referred to the FTC.
CARU REFERS VIRTUAL FAMILY KINGDOM TO FTC AFTER COMPANY DECLINES TO SUBMIT RESPONSE TO INQUIRY

Basically, CARU found that VFK was not COPPA compliant and that it didn't follow through on promises that were on its web pages at the time of review.  The press release is pretty sparse, but this is not a good sign for this game.  Anyway, I was pretty shocked even though VFK isn't all that big at my house - we're more build-a-bearville people these days, lol.  But I thought that anyone with kids in the game at least deserved to know.

As I Highlighted in your post, what is your source regarding the VFK review made during the "summer"?  I didn't find any reference to this timeline in the CARU press release, or on the CARU website?

Do you happen to be Christina "Tina" Poturica-O'Neill that is listed on the CARU website?

[PrincessWendyBird]

I notice this press release was dated Oct.16,2008, one month ago. I don't know exactly when CARU looked into things, as it is not stated anywhere on their web site, but I do know that when a child registers for VFK, an E-Mail is sent to the parents E-Mail for verification and approval before the child is allowed to enter the game.

[TikiTina]

No, KingQuackAttack, that's not me.  If I worked there, I wouldn't just be finding out about the report this weekend!  I'm a former VMK player who's been lurking here since early 2007.  I'm more active on other forums (or was back when VMK was running), but like I said I picked this one to post on because this seems to be where most of the grownups hang out.

Heh, as for the time frame; the actual case report (which I didn't bother linking to because you need a subscription to view it) was published at the beginning of October.  I guess it depends on where you are, but around here Summer lasts right through the exinox near the end of September (and later sometimes, durn global warming).  We didn't start having jacket weather until a few weeks ago.  I guess 'some time in the last few months' would have been less confusing?  But I'm not sure why that's all that important.  When I saw the press release this morning, I thought that the people whose families play this game deserved to know about it, so I posted it. 

And Wendy, parental notification was not the only issue raised in the report.  While they seem to be doing it now, the registration form was not always set up like that.  A google search for 'vfk coppa' turns up a post from this forum in July saying that at that point they were still collecting email addresses of under-13s.  So while they may have fixed that problem now, they could still be looking at a heafty fine.  Just look at Lil' Romeo.  Who knows how many kids emails VFK collected in the first few months they were online?

[PrincessWendyBird]

Well, thanks for the information TikiTina and a belated  to posting here and becoming a lurker no more. 

I suppose VFK will have to deal with those situations as they arise. Until then, I will keep enjoying the game with our family and playing as we have all learned to play online since the close of VMK - enjoying the time we have in game knowing they can leave in a flash. I certainly hope VFK succeeds as we have three generations who play together in game and know many families who feel they have found a new online home.

Thanks again for your information and we hope to see you posting around the other areas on NoBS in the future. Lots of fun over here with us "big kids". 

[KingQuackATac]

Well, ty for the clarification. So good of you to be concerned. I guess like CARU says in their guidelines:

"Although there are many influences that affect a child’s personal and social
development, it remains the prime responsibility of the parents to provide guidance
for children. Advertisers should contribute to this parent-child relationship in a
constructive manner."

......it's the parents who should protect their children.

I'm more concerned about the commercials on TV during family programmig/sporting events, than a family-friendly game with limited-word chat that does exactly what CARU suggests:

"Advertisers are encouraged to capitalize on the potential of advertising to serve an
educational role and influence positive personal qualities and behaviors in children,
e.g., being honest, and respectful of others..."

[TikiTina]

Sure, non-G-rated commercials at times when kids are likely to be watching are a problem.  But 'doing exactly what CARU suggests'?  The press release indicates that at the time of review, the game was not COPPA compliant - in other words, it was not taking the proper steps to keep its younger members safe and to protect their privacy.   They're still not there, incidentally.  They're supposed to have full contact information including the name (although most sites seem to get away with the office or a job title) and mailing address of the responsible party listed in the privacy policy.  It's not even clear from VFK's site what state their offices are in.  And this after their big announcement in that pinned thread up there about how their 'backend' is 'aimed at COPPA-compliant moderation.'

And yes, parents should take responsibility for reviewing what their kids do online (or what commercials they're exposed to), but the fact is that COPPA is the law, and VFK didn't (and still doesn't) follow it.  You just plain can not collect an email address from someone under 13, and that's what VFK was doing for a good long while.   The 'it's the parents' job' argument has its points, but it doesn't excuse VFK's apparent decision to ignore their legal obligations. 

If they didn't pretend to be taking the expected measures, that would be one thing, but they made claims about safety features and then didn't follow through.  If kids were exposed to unsafe behavior because a parent reviewed the game's 'Kid's Privacy Policy', which "referenc(ed) practices which (did) not currently exist" and used it to make the decision that VFK was a safe, responsible game, then that's a serious violation on VFK's part.  It's a lot easier to turn off a tv than it is to navigate a mass of conflicting and inaccurate privacy policies and parent faq pages. 

And thanks for the Welcome, Wendy! That's such a cute picture. :-)

[Happy]

This post has me wondering just how would VFK be able to comply with regard to the emails collected before the game opened.  If it is determined to be a complaince issue by the FTC, would they have to have everyone do some type of "re-confirmation" process, perhaps before they go to another phase such as "gold"?

What do you think? 

[PrincessWendyBird]

Interesting idea Happy. That might be the only way they could work out a compliance for those registrations if the FTC does decide to do something. This is really all in the hands of the FTC and VFK at this point. The press release is a month old, but I am not sure how quickly the turnaround works on those things. Time will tell, I suppose. 

[littlebelle]

I do understand the need for COPA but any 8 year old could get around the rules if and only if the parents were not paying attention. Thus if good parents are doing there job they would have already checked out the site. Visa versa bad parents would never know because their kids have already learned to go behind their backs.

I tell you we limited Adam's computer to one hour a night on weekdays and once home work was done he could play most weeknds. BUT and a big but he had to be ready for a spot check at anytime. And yup we found some not so nice sties. But we nipped it in the butt. Because we kept a watch on him. And yes I did have an email address through hotmail that he used.

I personally think COPA is there to protect the site owners and not kids. Fortunately I was able to stay one step ahead of my son in knowing how to search history, temp files and cookies. His dad had no clue so yes he would have gotten away with it. No we would not have gotten your son has joined up on this site. Please confirm.

They only true way to protect the kids would be to need a credit card to register and or a proper internet provider email. Like here in Canada. Rogers, sympatico. One that you can only use if you are paying for their internet service.  Not hotmail or google. Then I think COPPA makes sense.

[DreamTulip]

This is now on the VFK site http://www.virtualfamilykingdom.com/privacy_policy.htm maybe as a result of this?:

"Virtual Family Kingdom Privacy Policy
Effective November 18, 2008
Virtual Family Kingdom is managed and operated by Virtual Management Consulting PTY LTD Windsor, NSW 2757 Australia, ("Virtual Family Kingdom").

This Privacy Policy describes the use of information by Virtual Family Kingdom.

Virtual Family Kingdom is a website which is safe for all ages. Our primary goal is to maintain and keep safe any private information that we collect on the Virtual Family Kingdom website. Our privacy policy and our information practices are compliant with privacy protection laws and legislation including the:

United States Children's Online Privacy Protection Act (COPPA)

European Data Protection legislation

Canadian federal and provincial privacy legislation

This Privacy Policy describes the Virtual Family Kingdom website information practices, including how we collect, use and disclose personal information.

About the Information We Collect
As part of our initial registration on Virtual Family Kingdom, we collect the following information:

Data that is collected at registration for children under 13:

Date of birth, User name, Proposed character name, Character gender, Password, Your first name, Parent's email address


Data that is collected at registration for all others:

Date of birth, User name, Proposed character name, Character gender, Password, Your first name, Your last name, Email, Zip or postal code


When a registered member of Virtual Family Kingdom purchases a membership, additional personally identifiable information ("PII") from the registered member or the registered member's parent may be collected.


The types of PII that may be collected at that time include:

Members full name, e-mail address to use for membership account, credit card billing information including mailing address and phone number, and such other information as may be necessary to process payment.


The Virtual Family Kingdom website does not require any further information from a member including children under age 13 to participate in any part of the website.

How we notify parents of children under 13 if their child has created an account on Virtual Family Kingdom:

Virtual Family Kingdom website requires players to give a parent's valid email address when they create their account. This e-mail address is used to send the parent a message in email that they must act upon to complete the registration of their child's account on Virtual Family Kingdom. So that parents are aware of our privacy policies, the email includes a link to this privacy policy in the message and information on how to contact us.

We may also use the email address to send messages and information about your account or notices about Virtual Family Kingdom and its related companies and affiliates. The email may also be used for any other purposes described in this Privacy Policy. This email address is associated with the registered account user name.

We may also ask for a user name and email address when a registered user submits a communication through the "Contact Us" form of the Virtual Family Kingdom website so that we may answer any questions or reply to comments.

In cases where players can contribute opinions to surveys and polls on the website, players may be asked to provide data that is not considered PII, such as favorite choices and country where player resides. Registered players can participate in the online chat on the website, however measures have been implemented so that players cannot provide personal information through the online chat.

Passive information that we collect on registered users includes certain non-personally identifiable information about the player's computer, such as the players IP address, the type of web browser, the type of computer operating system, and data regarding the player's Internet service provider. This information may be associated with any PII that we have collected and as a result will be treated as PII.

For players with paid memberships, the financial information collected as described in item 6 of this Privacy Policy is not used for any other purpose than processing payments to Virtual Family Kingdom. Any financial information that is required and entered when purchasing a membership is not maintained or stored on Virtual Family Kingdom servers. It is only on the secure servers used by the payment processing company for the reasons of processing payments made to Virtual Family Kingdom.

If the personal information necessary to create an account is not provided by a player, then Virtual Family Kingdom may not agree to provide membership and/or access to some content and features on the Virtual Family Kingdom website. In addition, we may not be able to provide other services, functionality, information, or products which may be requested.

How We Disclose, Store and Use Collected Information:
Besides the purposes outlined in Item 1, Virtual Family Kingdom may actively collect and use email addresses and user names to monitor and track usage and player compliance with the website's Terms of Use and Rules and Regulations.

The registered player's email address and user name may also be utilized to enforce compliance with the Terms of Use. This enforcement may include suspending a player account temporarily or permanently from the Virtual Family Kingdom website if a player fails to use appropriate behavior on the website. In addition, registered player email addresses and user names can be used by parents of children under 13 to enable parents to review PII that the children have submitted to the Virtual Family Kingdom website. It may also be used to notify registered players or parents of any information regarding the site, such as any amendments to this Privacy Policy. The aggregated information may also be used to analyze statistics and usage on the website, and to offer programs, products, or services related to Virtual Family Kingdom.

Any collected information may be disclosed if required by law, for example, in reply to a subpoena or court order. We may also need to disclose information to service providers or companies providing support for the operations of the website which would not be used or disclosed for any other reason or purpose. We may also disclose PII in reply to a public or law enforcement agency's request including schools or children services, to the extent permitted by law. We may also disclose this information if we feel that by doing so, it would protect the safety of a child who is a player on our website, or to prevent the instigation of a crime, or to facilitate a public safety related investigation, or to protect the security of the website, or to enable us to take reasonable steps to reduce liability.

In the event that Virtual Family Kingdom is sold in entirely, or in any part, or that or is involved in any business restructuring or merger, PII may be transferred to a third party associated with that transaction, as permitted by and in compliance with applicable law.

Finally, for reasons of security PII may be transferred and stored outside of the jurisdiction of members of Virtual Family Kingdom.

Information Collected for Third-Party Sites, Affiliates and Sponsors
We do not allow any third-party companies to directly advertise, or solicit to players on our website. It is our intention to not allow this kind of direct advertising in Virtual Family Kingdom.

Unique Identifiers and Cookies
Unique identifiers or "cookies," are small text files that are placed in player's computer browsers to store preferences. Cookies do not collect or contain any PII, however if we link these unique identifiers in any way with your other PII, they will be treated as PII. We may use unique identifiers to track such information as number of players, usage and tracking of frequency and what sections and parts of our site are visited.

Security Policies and Procedures
We have implemented physical, managerial and technological policies and procedures to keep all information and data collected and maintained by Virtual Family Kingdom secure. These measures safeguard against unauthorized access and ensure that we use the information we collect online correctly and appropriately.

Financial Information
As noted in Section 1, when you decide to purchase a membership, we will need to collect additional financial information at the time you purchase. Virtual Family Kingdom does not store the financial information, but instead, it is collected and stored by our payment processing vendor for the purpose of processing payment to Virtual Family Kingdom. All financial collection is secured by the safest measures available and will not be used for purposes other than processing your purchase. The payment processing vendor maintains the strictest security and confidentiality of your financial information. In addition, that information is safeguarded with appropriate security. Our bank is also subject to all the privacy laws which apply and relate to providing financial services.

Access to Information, and Objection to Information Collection and Retention
Please contact our Director of Privacy identified in item 8 if you would like to gain access to your PII that Virtual Family Kingdom has collected for you or your child. You may request that we delete, make changes to, or no longer maintain or collect the PII we have collected. In addition, if you may request information or contact information on any organizations to which we disclose PII.

When requesting information, please include your email address and a telephone number where you can be reached. As additional security measures to protect the privacy of your information, we use measures to verify your identity before allowing you to access the PII that we have collected on you or your child.

Contact Information for Virtual Family Kingdom
To send any comments or questions about this Privacy Policy, just send a message in e-mail with your questions or comments to support@virtualfamilykingdom.com or write to us at:

Virtual Management Consulting PTY LTD

109 Hanckel Rd.

Oakville, NSW 2765 Australia

954-349-3325

Any personal information that you provide in messages to the above e-mail and postal mail address will be kept confidential and will not be used for promotional purposes except upon your request.

Privacy Policy Effective Date and Updates
As of November 18, 2008, the Privacy Policy outlined above is effective and applies to all information obtained by Virtual Family Kingdom to date. The Privacy Policy may be changed at any time at our sole discretion. Any changes will be posted as the new privacy policy on the Virtual Family Kingdom website with the effective date clearly displayed. As required by applicable law, PII will not be used in any way that is essentially different from the uses outlined in this Privacy Policy without notification of additional uses and obtaining consent for those uses."

~Dream

[KingQuackATac]

Well, I think I finally have an excuse to take my family on vacation to sunny Austrialia now!

Woo Hoo!!!! 

[Astro]

Dream, Yup ~ I believe so too.

Sorry I didn't see this post first, we must have seen the revision on the privacy policy at the same time. 

[PrincessWendyBird]

Dream, Yup ~ I believe so too.

Sorry I didn't see this post first, we must have seen the revision on the privacy policy at the same time. 

Actually Astro, this is great! I was going to post a copy of the new privacy policy to this thread also, because it pertains to this topic!

So kudos and awesome finds Dream and Astro!