Digital Media for Children - Keeping the Next Generation of Gamers Safe | PGC Digital #1

so hello everyone welcome to our panel digital media for children keeping the next generation of gamers safe so this is a really great topic we have you know really esteemed speakers who in this the children's industry day-in day-out as Oscar mentioned my name is Jen coming I work for a global video game developer called MC soft were based in South Korea although we don't you know work in the kids industry however because we are in the video game industry these children's regulations developer guidelines things that we'll go over today so I always keep an eye on to make sure you know that we're steering clear of any any of these regulations so what I'll do is I will have each of our speakers give a brief introduction to themselves you know their industry and then right after that we'll jump right in so Karen maybe we'll start with you see and consumer

regulatory affairs for aristocrat digital which is the parent company for big games and product happiness UK I've been an in-house attorney for over 15 years and what I'm somewhat new to the mobile gaming space joining aristocrat just a little over a year ago tons of quite a the experience though before this I worked in consumer facing industries and social media people search and loyalty rewards rewards and I'm currently based in the big fish games office in Seattle or rather my living room in Seattle but generally I work in a big fish based office and the apparent distance I think your camera might be turned off I know zoom automatically kind of turns it off upon joining so you might have to manually turn on the camera yeah I'm working on that it was on and when I was promoted to panelist it lost the video zoom is showing my cameras being on okay well

I'm sure we'll try to figure that that out in the background but maybe shy you can carry on with the introductions sure so my name is Shai Samet I work with the company called kid safe the kids safe seal program particular we are a auditing and certification firm for compliance with best practices for online safety and privacy including most notably the Coppa rule here in the United States and so we are a safe harbor approved entity by the Federal Trade Commission our mission is to help improve the internet and digital ecosystem for children around the world and we do that by partnering with industry with developers with operators companies of all sizes across the children's media vertical in helping them design their digital properties including their websites their mobile apps connected devices etc in compliance

with with privacy laws and best practices so that's that's who we are we have hundreds of members worldwide across all verticals including web mobile connected devices AR VR except robotics and anything you can think of in the digital attack I should say as well and we work with lots of gaming platforms too so that's that's moving Thank You Marie Connor hello everyone my name is Mariana I'm a CEO analytics is a text analytics company and we provide moderation tools for online services and for the gaming industry and my own background is visual intelligence I have PhD on machine learning and

computational linguistics and I've been on the field for over 15 years now thank you so today you know I think we have a really good kind of global panel here and we're gonna talk about you know the first item is very US Turkish there's kapa the Children's Online Privacy Act which is you know kind of plays a central role in a lot of children's issues in the US market next we'll talk a little bit about how cops and enforce and kind of change the way that we view the children's market through the talk and YouTube cases then we'll dive into the Apple Google development guidelines and lastly you know also touched upon kind of the European guidelines Jew DPRK and the UK age appropriate design code and so we you know have a lot to cover but we will try to leave the last five to ten minutes for Q&A however the chat feature if you have any

questions during the presentation you know we'll do our best to kind of address some real time so please don't be bashful and with that you know again like I said Coppa place up to key role Karen maybe you could kick us off and give an overview of the u.s. or unnecessary of killed r''l information my operator is internet websites online services yes your games available either the web social media or mobile eyes to

these operators either children or that have actual knowledge that they collect use or disclose his personal information from kids I'm getting bad keep is anybody else here you see back yeah I'm hearing that as well I'm not quite sure what's causing it are you able to understand just just yes so copy requires businesses to do a couple of things post a privacy policy that is clear understandable and complete provide just time notice parents if it's information processes and obtain verifiable parental consent prior to collecting using or disclosing personal information from

kids they also have to delete personal information for kids at the parents frequency cap has been in effect since 2000 it was revised from 2013 and late last year the Federal Trade Commission held a workshop to explore whether or not Coppa was working and if changes needed to be made I'm sure psy has some ideas on what we may expect coming out of this some of my ideas are that there may be a broadening the definition of personal information to keep pace with changing and evolving technology potentially an increase in the age age target particularly those older teens like 13 to 15 maybe not for parental consent but maybe requiring self anibal's tops of data breach notification

requirement where particularly in the EdTech space if there's a data breach related to children's information that they've got to provide rental because we know data breach laws in the US are state-by-state this would create a federal standard at least as it relates to children shai do you have other thoughts yes I'm happy to share some thoughts around around Coppa in its current form which is the version 2.0 of copper and what we might see in Coppa 3.0 as Karen mentioned the copper law is currently under review by the Federal Trade Commission that process was kicked off last year following the the YouTube settlement or in conjunction with the large YouTube sediment which we'll talk about in a little bit more detail later on and the FTC typically looks at Coppa

every well technically every 10 years but they've been accelerating now to every five to seven years the last time they did an update to Coppa was in 2013 and now they kicked off another review which I think will end up resulting in what we'll probably call Coppa 3.0 I think the key areas that are being evaluated right now are one the overall impact of Coppa first and foremost is the Coppa law working in its current form has it been beneficial to children does it need to be overhauled what has been the cost of implementing Coppa particularly on small businesses and I think you know in looking at the bigger impact the FTC really wants to understand from industry has the Coppa rules caused fewer kids websites and mobile apps to be available in the marketplace because of the challenges of compliance is it is it resulting in

unless content and digital play for for kids so that's one I think sort of overarching area that the FTC is going to look for secondly I think I think there's going to be a bit of clarity and clarification desired around what does it mean to be directed to children or to have an app that is directed to children this really came about through the YouTube settlements where there were many or there apparently were many channels that we're being visited by kids consumed by kids but YouTube was taking the position that kids are not using their platform well they're certainly not viewing the content by themselves which the FCC obviously felt otherwise about so I think we're gonna see some additional clarity around what does it mean to be directed to children and hopefully they have to see a little better clarify what are the different categories of directed to children what

does it mean to be a mixed audience app for example versus purely and primarily directed to children and there's some other areas that the FTC is gonna look at very closely including the definition of personal information should that be expanded to include things like biometric data face scans you know iris scans fingerprints etc should it include voice commands should there be explicit exemptions when you're using a voice enabled technology where the child's voice is uploaded such as to Alexa and then converted to text but then the voice recording itself is dumped and then I think the FCC finally is going to look at the internal support exemption that's the exemption that allows you to collect and track things like analytics without having to get a parents verified consent you have to see we'll look at should that be expanded to include things like advertising and attribution which is a very important tool for

developers in the kids app category to be able to use and then lastly as you mentioned Karen I think the FTC will take a closer look at education technology at Tech should that be treated differently should schools be exempt from having to get or give explicit consent to the use of certain educational services in the in the school context so anything that's particularly relevant now with so many kids being home and gravitating towards those types of tools today so I think that's that's a lot to digest and it would be interesting to hear from those who are listening on to this panel kind of the level of Coppa knowledge and expertise that you have and whether we need to take a step back and talk moralistically about some of these specific requirements agreed I think the beauty of kind of having this panel is that you know can it can be very conversational and we can tailor according you know in live in real-time

kind of what the audience needs so again any participant please feel free to use the chat feature so sure as you mentioned it's a lot to digest there's kind of the current landscape of Coppa there might be the upcoming changes in Coppa so for example Karen when you know a big fish if it's a new business team comes in and says hey we have this project we want to do XYZ you know what are kind of the initial you know threshold questions that you ask or the key factors that you look at to figure out does Coppa come you know even apply in that situation so similar to what you mentioned yan and your company's philosophy is big fish does not make games for children or targeted to children we had an exception when we partnered with Disney last year and created a new match 3 game called Toy Story draw for the most part our games are targeted and intended only for adults but whenever they come in with a new idea and reinforce that message but I'm looking at things that the FTC may

see in our game that may change or make them think that our game is you know targeted or interested or appealing to kids or users that are under the age of 18 I'm looking at our assets particularly those that we're putting in the App Store I'm looking at our App Store description and making sure that it aligns with our Terms of Use and our age requirements there I'm looking at you user acquisition and our ad partners to make sure that we're targeting only 18 and up so we're really just making sure that our game we stick with our target audience of 18 and up and that there aren't anything that would accidentally or unintentionally be appealing to kids or to refute the fact that we you know really and truly only want users that are 18 years old and older with the exception of the story make sense and so when you have members come to you with their content is it a similar analysis is there are there different factors that you look at

well in a lot of ways we perform a similar analysis at least with respect to casual games or games that of the kind that big-fish launched is where it could appeal to a you know general audiences people of all ages and so but for the most part the companies coming to us you know given our name given what we do gave me what we certify more often than not they're already coming to us with an app or some kind of digital experience that's specifically designed for kids a lot of times companies will come to us with a educational oriented app or even a family oriented app where there could be elements of the experience which are meant for the kids to watch consume interact with and that elements of the experience the parents are meant to engage with for example you could have a learning app where the kids the one consuming and playing the games and learning the ABCs learning a

language learning math for example and then the parent is the one with whom the app developer wants to communicate with about the child's learning progress in using that app for example and so there could be a dual experience often times we work with a number of social apps where it's kind of a mini social network within the family and so there are kids using it but also parents and grandparents and so the any question that comes up in that context is can an app developer tailor or follow the the Coppa specific requirement with respect to the child user but then when it comes to dealing with the parent user you know tailor that experience differently and perhaps ignore or overlooked or not have to deal with the same Coppa specific requirements in that context and this comes up also when you have for example

companies that sell some kind of hardware or physical item where the website is very ecommerce driven and they're trying to sell something to parents take a robotic device for example right you go and you buy it online on company website or on Amazon but in this case let's just say you buy it on the directly from the robotics company on their website and then when it comes into the home you download an app that's used by the child to control the robot to configure to set up and to code the robot to do certain things and so in that case you might have a web experience which is meant for the parent and the grownups but yet a different experience which is meant for the child and so it's important to think about that when you look at the copy requirements and whether for example on your ecommerce site can you drop a tracking cookie for example to do behavioral advertising or retargeting if

the site is exclusively directed to parents ok whereas on the mobile app obviously you could not do that type of thing because that's regulated by Coppa and that's the experience it's meant for children so this is also very relevant I think will provide a nice segue to talk about YouTube because you have a similar question that arises is when you offer you our content your child-friendly content on a platform that is not just for kids it's meant for the masses and so there are platform elements that YouTube will offer that would appear to be totally not copper compliant but you as a channel operator with content on YouTube have to look at and consider what are my Coppa expectations and should I disable for example certain features if I have content on YouTube so we can we can talk about that more when we get into the YouTube conversation yeah I think you know you briefly touched upon a couple of different

elements and so I think now let's dive in to kind of real time examples so what I'll do is I'll play this clip and then the audience you know using the chat feature you can just type in your answer if you think this is directed to kids not directed to kids if you're unsure kind of based on those Coppa elements and kind of the analysis that Karen and Shai I kind of went through yeah try testing us earlier but my audio seems to be having issues I think actually the audio in this case yeah Eon is probably not critical so yeah should be fine so if you look at the different

elements this channel is called you know dude perfect it's for a channel friends who you know do cool things and hang out and this is one of the the videos on their comments so um let's see if anyone so well I guess just ten seconds for the audience to decide if there's directors kids not too kids are unsure no responses yet but maybe shine here and you guys can dive in and you know what elements do you see here what's what's your verdict so there's a couple of things in here that make me think that the at least in the FTC's opinion that there is at least an argument for the FTC to say that this is directed at kids I have three teen tween agers who were wildly into the bottle flipping competition so I know that that was a huge pop culture reference with kids as young as seven and eight years old and

also the inclusion of small children in the video may make an argument for the FTC to say that it's at least general audience and that could include some children shy what do you think I think I think that's right I mean I think if you look at the video as a whole there are elements of it that would appear to be attractive to to kids including the bottle of flipping activity itself along with the presence of kids and and sometimes music and the soundtrack could be relevant although in this case I don't think it was so I agree I mean I think there are elements of that would seem very attractive to kids but when you look at dude perfect as a channel and you look at their content across all of their videos you know it's very hard to make the argument that this is made for kids or at least made specifically for kids because they're doing all kinds of sports activities

which appeal to all audiences especially men but perhaps women as well across all ages I love watching do perfect myself and so I think for a YouTube channel to label themselves made for kids they have to feel that they're creating their content specifically for kids and not for others and when you start to think about it in that way you know you you come up with Nursery Rhymes cartoon videos videos that are based on IP that are you know popular among kids videos that are put together by a young celebrities that are very popular among amongst kids and so I think dude perfect has not marked their channel or I don't think any of their videos specifically

being made for kids and I probably wouldn't do that either given given their audience yeah based on this if you guys you know open to YouTube mostly there's ads they do have ads for purchasing dudes perfect be sure they had open comments so I think you know in this instance the channels kind of agrees with our our analysis that's you know they do not want to be categorized as directed towards children all right so with that knowledge and experience we have a second video this one is a little bit more sound dependent at you know so essentially this is an Atlantic Records video and what they have is pink singing with her daughter singing a song from the greatest showman you have to use your imagination here [Laughter] and you know pink kind of goes into that she didn't have these opportunities and

she was a kid and so you know they've made this great movie really excited you know to have this opportunity you you actually click on that little eye that's appearing in the ad on the top right of the ad not that one the actual no no no the one that appears in the ad itself yeah there you go okay thanks so going back to that so you know again Karen what are thoughts what do you think of this video well you know given the presence of a youngster singing again I mean there's there's room to argue that it should be treated as made for kids

but you know kids who sing appeal to older users as well just as much and and so I think I mean I can tell from the features that are available on the video player itself whether it's been marked for kids or not in this case it it has not been marked for kids because of the share widget that appears in the top right and because of the ads including Google's estimation of your interests right which suggests that it's targeted based on previous you know channels you've seen or previous websites you've been to so again it's tricky and I think if I think to me if you look at the FTC's guidance on this which there's an abundance of now along with some of the videos that YouTube has put out about how to label your your content and based on what I anticipate to be the

FTC's enforcement approach and who to go after if your site if your content if your YouTube channel it's clearly for kids and only for kids I would mark it as made for kids and if it's not you're likely in a good position to preserve it as not made for kids and be able to take advantage of the features including targeted advertising personalized ads now I just want to raise one thing before we move on to the next subject yon because we are talking in a gaming conference and there are lots of gaming channels on YouTube and and sometimes those gaming channels are facilitated are run by kids who are playing video games you know with that with and sharing their video game screen at the

same time and walking through what's happening inside the game and then you've got a lot of gaming channels which are run by older older people gamers hardcore gamers in their 20s in their 30s and also playing games which some some games which are popular amongst kids and I think in the first category where there are kids playing games and they're playing kid games you have to assume that those are videos and channels that are directed a kid made for kids and label yourself accordingly once you get into the older users or the older influencers who are playing these games you know I think you have to look at the game that's being played for example if it's if it's a game that's very popular amongst kids and only kids then and perhaps that particular video should be labeled as made for kids and disabled all of the copper violating features on the other hand if it's a game that's meant for older users or

people of all ages including kids is when you can probably label it not made for kids and continue to take advantage of the features that including personalized advertising contact so it's a very case specific analysis case-by-case analysis that you need to do when evaluating whether your content is made for kids are not on YouTube yeah and I know you know we spend a lot of time on Kaaba in this discussion but I think you know it's really helpful in this one you know digital world as well as a lot of this social media sharing I guess one question I had was so when I found this video I actually found it on the kids Channel but obviously to embed this into kind of the Google slides I think it is there a chance that this video was both on the you know the regular general audience YouTube and then a separate kind of copy on the kids channel and so on the kids channel they're not collecting their information there was no availability for comments but in this instance this

one was for a more general audience who's that happen it's possible I mean there could be there could be features it there are some features by the way that you can disable regardless of whether you actually mark yourself made for kids on on the YouTube tools so for example you could disable comments for your video it's automatically disabled if you mark yourself label made for kids but there are certain features you can disable regardless of how you mark your content so it's possible some of those features have been disabled typically when you embed the YouTube player into into a third-party application like Google slides be function in the top right and how to share function if it was marked for kids so that's why that's what let me to think that maybe this hasn't been marked that way got it thank you really helpful really all right so

you know Coppa and technology I think oh so we actually got one question how do you think 15 kids safe in VR differs from other games it's all much more immersive does that mean VR needs a different approach which kind of kind of goes in her and excites you with Papa and new technology how do we address VR yeah and I think Maria will have will have some things to say about this as well I mean once you go into the VR space so you've got to think about as an example audio chat and whether you make that available to kids because audio chat a child's voice live or recorded is considered personal information and can't actually be collected and streamed and shared with other users or even heard by other users unless there's enough the front verifiable parental consent that's obtained from parents in a way that meets the requirements of content and we've gotten into that we could but I think that's one key

consideration and in fact we work with a company called rec room it's a popular hangout recreational VR game and they have what's called a junior mode and so when you sign up for rec room and come into the VR experience if you're under the age of 13 you will disable audio track and and the reason for that is because today unlike with text chat or even you know the TiVo chat or things like that where you know mate you might share some photos etc there really are no scalable and automated tools to remove in real time or to obfuscate in real time a child's real voice or to prevent them from sharing profanity or personal information through that live voice chat so that's the issue one issue you encounter at all I'll bet Maria

talked about this as well I just want to point out one more thing which is I also in VR what's interesting is that in in the in the web world in the mobile world one of the things that we do today for age screening is we simply ask for a date of birth there are some newer techniques that can be used today as well but for the most part most casual games out there that might be mixed audience will just ask for age when you first launch the app and sort of take you into a split experience when it comes to VR there are some pretty neat things you can do looking at biometric data to determine the age of your user Apple you can you can determine potentially the height of a player in VR or if you're using the handles in VR the distance from the torso to the heads to determine whether it's a longer or shorter arm and thereby be able to detect whether it's a child who's

playing the game now of course if somebody's sitting down or único have been forbade they're in a wheelchair there could be also negatives or false positive positives there but it's a very interesting thing to think about that VR affords us in being able to extract certain information about a person's age based on their biometrics within a VR world which is fascinating Thank You Marie fauna yeah talking about altering voice I suppose there are technologies to do that but but it is here the voice after after the technologies use it it's another question talk about personal information on kids and the voice being one of those I want to remind that in European area personal information can be even to nickname of the kid and adults as well so this kind of these

kind of definitions they change in income actually you I'd like to say something about it provide because um they help the developers to follow this legislation for example code as I said earlier utopia is a text analytics house and we provide real-time more recent tools to moderate content and the most important thing is to keep the toxic content out and if the target audience is kids also safety is something that is very crucial and technology works is that we don't actually define the motor-racing policy ourselves it provides our tools

everywhere in the world and our customers define how they do their motor race and they know best that local legislations all the laws and things we just provide the scaleable tool which is able to handle the high volumes of chat messages or any other kinds of new user generated content images videos anything and our tool lawrence from human decisions how to do tomorrow racism and I think this is one of the ways how moderation will be done in the future it can be done no race already this can technology expand this the only way to be able to handle the youth volumes of data online yes I think you know one one question is you know how do I comply what is carpet and even though I know the line you know how do I actually implement it and comply with it and you mentioned you

know a large amounts of data especially in this kind of Cove in nineteen crisis you know I saw this article that was really great that utopia analytics you know in response to Cove in nineteen with where online kind of communication has just exploded all of these social media companies you know need to need kind of they need assistance in kind of moderation and scaling and so could you talk a little bit about that you know how Koba 19 has really changed the landscape of kind of you know online communication in moderation yeah the volumes have definitely increased in some of the platforms but it depends on the industry but you're talking especially kids they are not at school and now they have time in many countries they are not at school and and no they have fun to talk with their friends and they definitely do that in the platforms and our customers who use

AI tools for that they don't have any problems because they just continue using the tools us it's not problem to have bigger volume but if you do manual moderation and at the same time perhaps part of your personal is sake or somehow I was not available for working it may be a situation that you need to cut down the the volumes in other ways and that is a problem if if your income comes from those yep I'm shy Karen any thoughts about this crisis and how you see you know Coppa or privacy enforcement changing evolving you want to yeah as I had mentioned before the increased use of these IDI tech games apps and websites because of the coded

situation I think will force the FTC to either expedite or take a closer look at some of the changes that they're contemplating in that area as far as enforcement goes not specific to children but certainly touching children is california the cbc ccp day act I know there's been several groups that have lobbied for a delayed enforcement which is currently set for July first the AG hasn't moved on that yet but I know they're getting increasing pressure from several industries and businesses they're simply just not ready for enforcement on July 1 because of the code and so I think we could see a delayed enforcement of the new California privacy law and I think the same is with cop you know with the FTC's rule rule review process currently underway and kick off in 2019 as it as it is it likely would have taken a full two and a half to three years by the time a new law would be effective and I

think you know this the crisis were going through right now is likely going to delay that I would hope would delay that further because the last thing the small app developers want to be dealing with is having to you know do more things to get to get compliant and especially now when their technology especially in the educational sector is seeing a huge boost because of kids being home engaging you know with more online resources than ever before so right now it's all about servicing those kids I think the FTC might be concerned long-term that that some companies out there will take advantage of the current situation and RB exclusive if you will I'm signing up you know new customer then for free now and then three months from now six months from now converting them to paying subscribers so I would encourage every company that's looking to do that to be mindful and strategic and wise about how you approach that and

of course only opted in new customers to a paying subscription after that trial period ends so that there isn't a lot of backlash on this yeah I have a question for you that I'd meant to ask in our previous kappadisco discussion I know that the workshop was in the fall public comments were open until the end of December obviously this was all pre coded but do you have a sense on when we might see thoughts or or hints from the FTC on future Coppa changes or do we have any information on time well as far as time is concerned in the last review back in 2013 which kicked off in 2010 okay it took them a year and a half after the first round of comments to produce a proposed what's called a notice of proposed rulemaking so a proposed revision and that would then be subject to further comments so you know I think we're likely looking at the same

timeframe and now perhaps perhaps longer but I yeah I don't know that it will be before sometime next year well into next year especially given the current crisis but before we see a proposed revision to Coppa unless again unless the FTC feels that given the surge in the use of online technologies for children because everyone's home that they want act more quickly to curtail you know what I mentioned before exploitative type practices that we might see in the industry right now thanks I so I know you know forty minutes has really just flown by Oscar do we have any room to kind of you know the last five minutes to breeze through the rest of our presentation or or I'm happy for you to keep getting every other five minutes maybe even a little bit longer we'll see okay awesome thank you just let us know when we meet you know when we get the hook okay so just

really briefly you know I mentioned enforcement seeing how ICC enforces Coppa oftentimes is here's a huge insight onto Coppa and so you know Karen really briefly forty talk what were the things that got to talking troubles that we can learn from those mistakes and what things that they have to implement as part of this kind of enforcement so in February of 2019 the FTC levied at the time which was the biggest C Coppa related fine five point seven million dollars formally called musically um for a violation of Kabul laws I think the important takeaways from this case were that the FTC deemed the app to be directed to children that is not surprising to me now that I've seen tik-tok and my kids have used it but another important factor there was tick tock admitted that they had thousands of complaints from parents putting them on notice and providing the actual knowledge that their app was being used

by children um they also had an informational section on their website that was directed to parents with tips on how they get how to have the kids use the app safely so when the FTC deemed them directly the children that was not surprising they were slapped from the 5.7 million dollar fine which was huge at the time nothing compared to what we're gonna see with YouTube and tick tock was forced to make a couple of immediate changes first of all they had to push an update to all users current and they hit you with an H gate immediately and once you entered your age you were worked in two different experiences and under 13 and in over 13 in the under 13 phase you there was no collection of personal information you couldn't publish videos - tik-tok or share them you can only like or follow other videos or users and tik-tok was required to remove all videos that have previously been published by kids that they knew were under the age of 13 so those were the practical effects that

came out of that settlement in addition to the 5.7 million dollar fine thanks Karen sure I do want to run through youtube quickly as well kind of same questions what's good is wrong what have we learned well you know it's really after the internet many companies come to me and almost cry with tears saying that a revenue gonna drop 80% I think on average since the changes that YouTube made to kids are effective channels revenue is down 50% on average around 50% so I mean it's a long time coming and you know I tried to reassure those those people by telling them look you got away with it for so many years you should be thankful for the revenue and the money that you made during that time frame I mean the bottom line with YouTube is that I think the most critical takeaway from all of the takeaways is that both for YouTube and

content creators you're now kind of equally liable the content creators can no longer say well I'm not responsible because YouTube is the one serving the targeted ads YouTube is the one that offers the features on their platform that doesn't work anymore if you've got a YouTube channel on YouTube it's akin to having a website on the web for which everyone agrees that you're responsible as the first party as to what happens on that website same is true with the YouTube channel and and YouTube equally can no longer say we're not the content creators we're just a third party platform so it's our problem and I think that's the key takeaway from from all this is that each each is equally liable and needs to ensure that their channel is is copper compliant thank you you know so with what kind of the changes you know with tick-tock YouTube just kind of technology in the

world changing in general Maurice Lana you know how do we keep these kind of community environments safe you know what are some minimum you know expectations that we should be seeing and are these driven maybe by laws and regulations are they by platform guidelines best practices maybe even you know even though no law is telling us to do it maybe we have a duty and a responsibility and ethics to kind of implement these kind of safe safe safety and guardrails for children what are your thoughts on kind of best practices and what we can look to in the future yeah I think the platform each platform hub to have their own guidelines how how their users need to behave and they also follow the rules legislation every country where they are but then since the amount of content is huge they need some AI tools to monitor

whether the users follow the guidelines and perhaps also monitor themselves whether their own employees follow the guidelines and they need to be ethical and responsible in a way that that they define what is good and what is bad in in the way that it lasts this kind of checking and monitoring so there has to be guidelines there has to be tools to monitor whether the guidelines are followed and there has to be individuals who take care of all the big picture in following ethics and you know you kind of mentioned you know meet the need for

each platform to really have their guidelines to define what is allow you know what is not allowed and I think [Music] Google and Apple you know have have kind of done that you know in the next minute uh-huh maybe you know Karen and Shai can you discuss briefly kind of what these updates that Google had you know with respect to design for families Apple had the kids category you know what does it mean to fall into these categories and kind of what are the major highlights and importance of these guidelines I'll say at a high level that that if you are launching and releasing an app on Google or the Apple App Store that's going to be in the design for families category on Google or the kids app category for Apple you need to be prepared to evaluate the third-party SDKs that

you're using before you select those categories and that's because on the Google side there are some limitations on being able to use advertising networks that are self-certified with Google and on the Apple side there's a more stringent approach which is that you can't use any third-party analytics or advertising solution unless you can operate completely anonymously without even passing back an ID fa which most of the mainstream platforms out there require you to do to function so you know the originally that the deadline on the App Store was March of this year they pushed it back to June so there's a little bit more time now to revisit this but you know that's just I think the bottom line you got to be prepared to abandon and have limited options when it comes to integrating third-party analytics and advertising solutions if

you're in the kids category unfortunately that is the poor another step in it cuz we've run out of time conversation I mean this is something that I think a lot of us understand you can attention to but a lot of the detail you guys have gone into is really critical because we're not all trained lawyers we're not all trained kind of experts in every aspect and I can say it season was lucky enough to be involved with PlayStation Home when they were first talking about Pottermore the Harry Potter world and it was interesting kind of the stark difference between the approach and we were taking for general use and the approach that JK Rowling and her team to cover for that audience which is obviously a much younger one by the way thank you and by the way look about that thank you thank you all so

very much thank you