Marketing to children on mobile continues to be a tough balancing act with very real and potentially significant repercussions if not handled correctly, which is why big players are treading carefully even as they remain reluctant to abandon the space completely. 

?It's important for mobile-marketers to understand that any type of marketing to children is unfair,? said Josh Golin, associate director, Campaign for a Commercial-Free Childhood, an organization that supports limiting commercial access to children and ending child-targeted marketing. ?Children are more vulnerable to advertising than adults. And while kids may be increasingly adept at using mobile devices, that doesn't mean they understand how they're being marketed to.

?Marketers should also be aware that parents are increasingly concerned about privacy issues and mobile marketing to kids and that companies that target children directly on mobile devices risk harming their brands,? he said.

Experts agree that marketing to young mobile users is the most complex and sensitive mobile-marketing topic, due to the privacy and security issues the practice raises. Yet despite this tricky area, marketers continue to dabble in it, lured by the promise of connecting with legions of mobile-addicted youngsters.

 

Application makers have jumped into the fray, producing apps targeting parents who want to give their kids time-outs from their phones and tablets.

DinnerTime Plus is a free Android app with real-time remote monitoring and parental control features that lets parents manage and take control of their children?s smartphone/tablet usage habits and addiction. 

The app works from the parent?s Android phone or iPhone to link with up to two youngsters' Android devices. It gives parents the ability to easily lock and unlock their child?s Android tablet or smartphone during dinner time, studying time or bed time, without intrusive controls, no matter where they are. 

The app also comes with features such as real-time monitoring, app or device usage limits and detailed usage reporting for parents who wish to be more involved in guiding and understanding the way their kids use their phone or tablet.

?Even the most harmless game can become addictive and cause problems for the child and the family," said Richard Sah, co-founder, DinnerTime. ?As parents we see this first hand and wanted to do something about it. 

?Recent studies showed that kids can use a smartphone before they learn to write their names or tie their shoes,? he said. ?Eighty-nine percent of 6-9 year-olds are active online, and 14 percent of 3-5 year-olds tie their own shoes, but a staggering 57 percent know how to operate a tablet.? 

Parents often voice concerns that their kids are making unwanted in-app-purchases from games, inadvertently clicking on some mobile advertising and being redirected to an unknown site, viewing age-inappropriate advertising content, Mr. Sah said. 

Marketers need to implement safety measures such as confirming the user?s age, or gaining parental consent through the sending of a confirmation link to a parent or guardian's email address before anything is activated, the executive said.

Kuddle, a Norwegian picture sharing app designed for children, plans to launch a child-safe tablet with Microsoft on Dec. 1. 

The first device will be an iPad Mini-sized tablet priced under $100. The device does not permit downloading of games such as Grand Theft Auto or apps such as Snapchat.

Kuddle, which bills itself as a rival to Instagram, lets parents monitor what their children publish and keeps access to content restricted, preventing strangers from seeing and sharing pictures. There are no hashtags or comments to prevent online bullying and "likes" are anonymous.

But even the best app features may be overmatched against the skills of a generation of children who live and breathe technology.

?The fact is, it isn?t very difficult for children to gain free, unmonitored access to the Internet - even if their parents block it on their phones,? said Shuli Lowy, marketing director, Ping Mobile.  ?Wi-Fi hotspots are everywhere and there are many mobile devices (aside from phones) that can connect to them. 

?The key, therefore, is for parents to have early conversations with their children about how to use mobile and the Web in a positive, healthy manner.?

Before commenting for this article, Ms. Lowy asked that her remarks be preceded by a disclaimer emphasizing that she is not a lawyer and that her information is for educational purposes only. She urged those involved in tracking or marketing to children through mobile to seek legal council.

 

?The mobile ecosystem is massive,? she said. ?If you do not know any information about who your ads are going to, then it is easy to throw large ad budgets down the drain quickly.

 

?Owners of ad inventory therefore work to get as much information about their users as possible,? she said. ?Gathering data on a mobile user allows app developers to provide a better, more personalized service and dramatically increase the value of their ad inventory. In some instances, just one piece of information about a mobile user (such as their location) can literally double the value of an ad spot.

 

?The key issue is that COPPA laws do not allow marketers to disseminate personal information about children under 13, without verifiable parent consent.?

Under the law, personal information is defined as anything that can personally identify the child, including first and last name, a physical address, social security number, an email address or contact information, a phone number, a persistent identifier, or any sets of information which when combined can uniquely identify the youngster.  

The FTC recently added on to that definition geolocation information, photos, videos, and audio recordings. 

?When?s the last time you used a mobile app without submitting any of that information?? Ms. Lowy asked. 

 

?Those who want to be in full compliance need to ensure they are in compliance with the FCC?s Children?s Television Act, the FTC?s COPPA, additional FTC advertising regulations, CARU (Children?s Advertising Review Unit), the MMA Best Practices, and various regulations set forth by the MPAA (Motion Picture Association of America) and the ESRB (Entertainment Software Rating Board),? she said. ?That?s no small task.?

 

Products that are considered mature or possibly dangerous for children, such as alcohol, prescription medication and household cleaners, cannot be marketed to children on mobile. 

Mobile ad marketers, ad retargeters and other firms that are caught selling information or otherwise violating COPPA statutes can be fined up to $16,000 per infraction, Ms. Lowy said. 

?When the FTC issues a threat such as this, they mean it. In the past, the FTC has used heavy violation fines as a means to whip the mobile industry into shape. The most prominent case was when they issued fines of up to $500 per text message sent by companies who didn?t properly opt-in their customers. 

?There were several large class action suits and two infamous settlements with Papa John?s ($16 million) and Jiffy Lube ($47 million). Somehow, we haven?t seen much SMS spam since.?

 

The popularity of mobile television streaming has transformed the TV-ad landscape. 

?Kids now are watching TV shows individually on tablets and mobile phones,? Ms. Lowy said. ?Ads placed on those shows are therefore no longer targeting the third party?namely, the adult in the room.  

?Those ads are targeted and served impression-by-impression. The parent in the room is no longer viewing the ad?just the child. This brings up many issues related to child protection laws and has served as a challenge for sales people who are tasked with monetizing children?s TV.?  

The importance of minding the pitfalls of mobile-marketing to kids cannot be overestimated from a brand-image perspective.

?By not involving the parents in some way ? through some level of parental consent or approval ? a marketing plan can potentially face very negative blowback,? Mr. Sah said. 

?If the marketing campaign is deemed to be inappropriate to the younger audience ? which, of course, can be a very subjective determination ? then parents will consider the campaign to be an unethical intrusion to their children and will be very vocal in their opposition.

?There could be legal implications if the marketer does not adhere to legal guidelines to market to kids,? he said. ?They may also receive negative publicity with angry parents, low customer retention and ultimately create a brand that no one trusts if they do not market properly and responsibly to this market.?