Child-Directed App & Content Guidelines

To help provide a safe and appropriate service for children and meet obligations related to children, the platform uses tags to identify apps, content, and parts of the user interface (UI) that are likely to be considered child-directed. Apps, content, and parts of the UI are considered child-directed when they target children or appeal to children. This can include things like a children’s curated section, a movie geared toward young viewers, or a collection of children’s cartoons.

Since we expect that children will access things that are child-directed, each instance of the following must comply with applicable laws related to children’s privacy and child-directed services:

1. Content directed to children

2. Data obtained from children

3. Anything with a child-directed tag

You should consult legal counsel regarding your obligations. Refer below to the Methods of child-directed tagging the platform uses to make such determinations.

Our approach

Our platform is unique from other content aggregators in that it surfaces and curates specific content, not just apps. Although we don’t currently use profiles, we do use tags on apps, content, and parts of the UI that are child-directed (or that children are likely to access). Child-directed tagging ensures that areas of the UI intended for children only contain child-directed content.

The platform uses 6 types of child-directed tagging:

1. App tagging is used for applications that are directed to children.

2. Page, rail, and feed tagging is used for parts of the UI that are directed to children (e.g., a rail of child-directed movies, a page of “kids and family” content).

3. Content tagging is used for specific content that is directed to children (e.g., a particular game for children, a cartoon that kids watch, content that an app knows is being viewed in a child profile).

4. Continue Watching tagging is used for watch history data related to the Continue Watching platform feature.

5. App metrics tagging is used for app metrics data that supports targeted advertising and audience segmentation.

6. Ad call tagging is used for shared ad inventory data.

You can view additional details on how tagging is provided and received in the Methods of child-directed tagging section below.

Content experience

Child-directed tagging is one way that the platform curates content for different audiences. The first two examples below show child-directed content on child-directed pages. Only child-directed elements (e.g., content, apps, and parts of the UI) will appear on the rails on these child-directed pages.

Alternatively, some pages may have a mix of child-directed and non-child directed content on the rails. Other pages might not have any child-directed content at all.

Methods of child-directed tagging

Apps, content, and parts of the UI all require different methods for applying child-directed tags. Each method of tagging is provided by one party, received by the other party, and is shared/maintained according to the specific cadence detailed in the table below.

*based in part on metadata from Partner

App tagging

Our platform relies on all partners telling us if their app is wholly or primarily directed to children. Apps that self-designate as child-directed will be tagged and placed appropriately within our platform based on that designation.

If you designate your app as child-directed, the platform will tag all content from your app as child-directed content. Your app and its content will be accessible from child-directed areas of the platform, but they can also still appear in non-child-directed areas.

Even if you do not designate your app as child-directed, it may still contain child-directed content. In this case, those individual pieces of content will be tagged as child-directed using our Content tagging algorithm. However, your app itself will be considered non-child-directed.

Determining whether your app is child-directed

If you’re unsure whether your app qualifies as child-directed, ask your legal team, refer to your local and national laws, and check guidance from regulators, such as guidance from the Federal Trade Commission (FTC).

Child-directed app status categories

All app content partners must self-designate each app as one of the following categories. This designation will be used to determine the level of Content tagging that will be applied to the app. App categories will be reviewed on a periodic basis and all Apps must notify Comcast of any changes that affect their designation.

Page, rail, and feed tagging

Our platform editorial team will manually identify and tag any pages, rails, or feeds that are child-directed. We make editorial decisions (with respect to what is appropriate for children of different ages) based on our Content tagging logic and related subject matter curation factors.

Content tagging

To identify child-directed content, we use a standard algorithm based on a combination of age ratings and genre tags.

Content tagging data sources

The child-directed tagging algorithm uses several data sources. For content age ratings, we use the following sources:

• Motion Picture Association of America (MPAA) is an association that rates films based on their appropriateness for different audiences. Learn more about MPAA ratings.

• V-chip is a television set technology that allows people in the US, Canada, Mexico, and Brazil to block TV programs based on their ratings. Learn more about V-chip.

• Gracenote Children’s / Family Entertainment Genre tag is used to identify likely child-directed content. Gracenote is an entertainment data provider that applies this genre tag to programming that has a target audience of children up through mid-teens and that can be enjoyed without parental supervision. For example, Blue’s Clues and Hannah Montana would both receive a Children’s / Family Entertainment Genre tag.

• Kid’s iTheme is internally generated by Comcast based on Gracenote genre tags, and content tags provided to Comcast by Video on Demand (VOD) providers and Over-the-Top (OTT) content providers.

Content tagging logic

Expect your content catalog to be tagged as child-directed if:

• The app is tagged as child-directed.

• The content has a rating of TV-Y or TV-Y7.

• The content has a rating of TV-G or TV-PG

  • and has the Children’s / Family Entertainment Genre tag or Kid’s iTheme.

• The content has a rating of G, PG, or NR

  • and has the Children’s / Family Entertainment Genre tag or Kid’s iTheme.

For advertising purposes, expect your media or listing to be tagged as child-directed if:

• The app is tagged as child-directed.

• The media or listing rating is TV-Y or TV-Y7.

• The content associated with it is child-directed.

• The station associated with it is child-directed.

Continue watching tagging

Consumers may share their viewing history between applications and the Comcast entertainment platform and can disable sharing at any time. Recommendation features can also be turned on/off by consumers at any time.

Content partners may share viewing history from their applications so users can continue content across all services in one interface. Where allowed, that data may also inform recommendations across the platform.

App partners sharing watch history with Comcast for Continue Watching must either refrain from sending child users content or include a child-directed tag consistent with guidance on sending tags for Continue Watching below, including data from children under 13 without parental consent.

Comcast uses watch history data and related tags to:

• Provide continue watching tiles within our experience.

• Restrict the use of watch history and any associated data in recommendation models.

Sending Continue Watching data

Include appropriate tags (including child-directed tags) with any data you send via Firebolt^® APIs if you have any reason to believe it came from a child.

Sending watch history data

Watch history data powers Continue Watching and recommendations features across the platform.

If you share third-party watch history data with Comcast and have reason to believe the data came from a child, you must send a child-directed agePolicy tag in the payload of the Firebolt Discovery.watched() API.

Some conditions where you should send child-directed tags with your watch history data are:

• The data was generated while logged into a child profile.

• The data was generated during playback of content directed to children.

• The data was generated during playback launched from sections of the app experience directed to children (e.g., playback launched from a children’s page, rail, or feed).

• You have any other reason to believe the viewer of the playback session is a child.

If you send a child-directed tag on watch history data, the platform will only use the watch history data to deliver Continue Watching tiles in children’s sections of the experience. Specifically, when you send a child-directed tag on watch history data, the platform:

• Will not use the watch history data to power content recommendation models.

• Will not use data derivative of the watch history data (e.g., click on the Continue Watching tile) to power content recommendation models.

App metrics tagging

The platform uses app metric data for targeted advertising and audience segmentation. However, the app metrics data needs a child-directed tag when the data comes from a child.

If you share third-party app metric data with us and have reason to believe the data came from a child, you must send a child-directed agePolicy tag on the data via the associated Firebolt Metrics method calls. All metrics methods except appInfo() support the agePolicy tag.

Some conditions where you must apply child-directed tags to app metric data are:

• The data was generated while logged into a child profile.

• The data was generated during playback of content directed to children.

• The data was generated during playback launched from sections of the app experience directed to children (e.g., playback launched from a children’s page, rail, or feed).

• You have any other reason to believe the viewer of the playback session is a child.

If you send a child-directed flag on app metric data, the platform will enforce child-specific delete requirements for the app metric data and data derivative of the app metric data. Specifically, when you send a child-directed flag on app metric data, the platform:

• Will not use the app metric data for targeted advertising or audience segmentation use cases.

• Will not use data derivative of the app metric data for targeted advertising or audience segmentation use cases.

Ad call tagging

If you share ad inventory with Comcast Advertising (formerly Effectv and FreeWheel) and have reason to believe that the viewer during the playback session is a child, you must send Interactive Advertising Bureau (IAB) flags, COPPA flags, or other child-related tags on ad calls to Comcast Advertising.

• If you use Comcast Advertising, follow the Comcast Advertising documentation for COPPA flag implementation.

• If you use any other ad server, encode macros to pass fw_coppa in the ad call.

Some conditions where you must apply COPPA flags to ad calls are:

• The user is logged into a child profile during the playback session.

• The content being viewed during the playback session is directed to children.

• The playback session was launched from an experience within the app directed to children.

• You have any other reason to believe the viewer of the playback session is a child.

If you send an appropriately encoded COPPA flag on the ad call, Comcast Advertising won’t return any targeted ads in response to the ad call.

Impacts of child-directed tagging

Child-directed tagging impacts app launch intents, content curation, advertising, and personalization.

The platform enables users to access their entertainment choices across different services in a single place. To do so, we lift content out of the applications, making it easier for consumers to discover content more efficiently. By understanding users’ preferences, we guide them to the content they want, no matter which service provides it.

By doing so we sometimes allow consumers to click on deep links directly into content, enabling them to launch into a particular part of provider apps/services. This gives us insight into what they are requesting to watch.

Impact on platform content curation

To make the experience easier to navigate, we also curate content by high-level interest or appropriateness categories, as well as user preferences—including favorited content, device interactions, past usage, and viewing behaviors.

One way we curate content is in child-safe and teen-appropriate sections. Only content with a child-directed tag will appear in child-directed areas (like Kids zone or eventually a child profile). Only apps that certify, in accordance with regional legal requirements, as being entirely child-directed, or apps with sections intended for children with proper controls around those children experiences will appear in child-directed areas (like Kid’s zone or eventually a child profile).

Content or apps with child-directed tags may also appear in non-child-directed areas across our experience in a non-discriminatory fashion.

Impact on app launch intents

The platform uses child-directed agePolicy tags to determine whether to send child signals on app Launch Intents. The platform will send a child signal when a user successfully:

• Launches child-directed app content from our platform.

• Launches a fully child-directed app.

• Launches an app from a child directed section of the UI (a page, rail, or feed).

Impact on content curation

Child-directed tags determine which content and apps are placed in child-directed parts of the UI (pages, rails, or feeds). These tags impact content curation in the following ways.

For content

• The platform only places child-directed content in child-directed parts of the UI (e.g., only child-directed movies go in a “Kids movies” rail).

For tiles

• The platform does not place app tiles for apps that aren’t fully child-directed in child-directed parts of the UI.

  • Exception: unless the app tile leads to child-directed app content.

• The platform does not place tiles for non-child-directed linear channels in child-directed parts of the UI.

  • Exception: unless the linear channel tile directs to child-directed linear channel content.

For rails

• If the Now/Next rail is presented in a child-directed page, the rail will only present child-directed channels.

• If the user selects “view all” from the Now/Next rail in a child-directed page, the user will land on the kids category within the TV guide.

Impact on the advertising experience

Child-directed tags and COPPA flags disable targeted advertising on child-directed content and in child-directed sections of the experience.

To ensure there are no targeted ads, the App must send IAB COPPA flags on ad calls made to Comcast Advertising. In response, targeted advertising will be disabled during dynamic ad insertion for shared ad inventory.

Targeted advertising will also be disabled for display advertising in child-directed sections of the experience (e.g., a kid's section) when our editorial team places a child-directed tag on that page, rail, or feed.

Opt-in/out status

Platform settings have an option to opt out of targeted advertising. The default status is opt-in, but child-directed content that is tagged as such and child-directed areas will never have targeted advertising, regardless of the selected status.

Impact on personalization

Recommendations provide users with content they might like to watch.

• Platform recommendations display the same recommendations to all users and are based on viewing data from all devices, while

• Personalized recommendations are based on the user’s watch history and are unique to the device.

We can use these recommendation features to generate an automated feed of content or to apply sorting to a rail that has already been created.

In the US, there are two main cases where we do not use children’s data to feed recommendations:

1. Children’s viewing events or resume points

2. Derivative data from children’s click or viewing data

Some content is always excluded from recommendations

Adult content, trailers, clips, and standalone sport events are always excluded from recommendations.

Additional resources

• Children’s Privacy page on FTC.gov