Refer-a-Friend Complaints

On August 22, the Center for Digital Democracy (CDD) along with 16 other consumer, media and youth advocacy organizations filed 5 separate complaints with the Federal Trade Commission (FTC) against McDonald's, Viacom Inc., Doctor's Associates, Inc., Turner Broadcasting System, General Mills and for violations of the Children's Online Privacy Protection Act (COPPA). 

The complaints call on the FTC to investigate these companies for unfair and deceptive marketing practices that use refer-a-friend campaigns to induce children to engage in viral marketing.  These campaigns invite children to submit both their own personal information as well as the personal information of their friends.  All of this is done on these child-directed websites without obtaining the express and verifiable consent of either sets of parents—a clear violation of COPPA.

The organizations also called on the FTC to update the COPPA Rule to address troubling new marketing techniques engaged in by some of these websites, such as placing third party cookies on children's computers to facilitate behavior targeting and collecting and storing children's photographs without parental notice and consent. 

View the cover letter and complaints to the FTC.  The complaints contain image examples of these COPPA violations.

Press Release

FTC Cover Letter

Complaints - McDonald's, General Mills, Subway,, Cartoon Network

For another example see the McDonald’s video below that contains the image of a child who has submitted their photograph on McDonald’s Happy Meal “Star in Video” feature.  This photograph was collected without a requirement for parental approval. 

The McDonald's Happy Meal website video
Click here for the video: