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2017: Let’s Do this

February 21, 2017 Leave a comment

Hello dearest internet. How are you? It’s been ages.

Ok, with 2017 – and the politically active (if not aggro in all directions) market has sparked activism in me. But I’m choosing that activism in the form of digital education. The social frontier is at a new level of everything: from awesome to horrifying. And magnified in tone and exposure.

In late April (perhaps early May), I am going to earmark a week for on-site assistance (starting with northern and central Illinois). I will be building three presentations (well, two, but three):

  1. PTO & Parents: Raising A Digitally Active Kid, what to know, do, and watch out for.
  2. Teachers: Understanding your digitally active classroom
  3. Kids/Assemblies: The Social Smarts of Playing Digitally With Others And Having a Blast

When I say “digital” I mean it in the form of SOCIALLY CONNECTED computer games, console games (consoles = XBox, Playstation, Nintendo, etc), ipad games/apps, iphone games/apps, tablet games/apps, mobile phone games/apps.

The biggest importance for me right now is arming parents with knowledge. Fear is not the goal – understanding and insights are.

Realities:

  • Disney, Nickelodeon, Cartoon Network: They all have youth programming that reference, center, or embrace social functionality in the digital space.
  • Banning social digital experiences makes them elusive to your child. Elusive things gain curiosity points. Where there is interest there is a will, where there is a will there is a way.
  • Trust (and amazing) preschool/kid-focused companies and brands ARE building certain levels of social features into games, apps, and experiences. It’s happening.
  • There are many kid-focused companies trying to teach netiquette.
  • There are many GENERAL AUDIENCE games/apps that people MISTAKE for “child-focused” — they may have educational value, or youth oriented aesthetics/play… but they are general audience.

One perspective: Would you allow your child to run to the open playground in the middle of the city unattended? Would you leave your child in that brand new over-crowded child pen without concerns in a town you’ve never visited before?

Another perspective: Are you going to make your child sit and look out the window as all the other neighborhood kids play in your front yard?  Kids cannot run out into the world during the summer anymore, and running about, playing in the neighborhood (don’t say YOU didn’t do this — I sure as heck did) — virtual experiences are the new forms of freedom play, and they’re growing in importance.

Bottom line: Don’t turn a blind eye. Embrace and educate yourself. 🙂 The best way to meet concern is to do so openly and with both hands on the steering wheel.

If you’d like your school or youth-oriented organization to get in on these presentations, leave a comment below. They’re pre-moderated, so I can review and contact you without exposing your information. 🙂 I will not post comments that have personal data visible.

 

Categories: Izzy Neis Links

Blogging Blogging Blogged 2013: Here I am!

June 17, 2013 Leave a comment

Dear Johnny/Molly/Henry/Willamena Fredericka II/Bubba Adelbert,

My apologies for the multiple names.  You see, you’re still too far away to even be a twinkle in my eye, and in my Disney-youth I princess-dreamed all the names I’d have for my future kids, so I thought I’d start with those (p.s. the II to Willamena is because I already have a Willa-dog. I love her desperately, so don’t take the “second” title as an insult. On second thought, I’ll budget for therapy, just in case).

Anyway, I digress.  Dear future muppet-of-mine,

I’m writing you now, well in advance, about a few things that worry me about the current state of our youth online.  Seems like an odd topic, right?  Yes, well, I figure that about the time you’re old enough to start using digital tools (funny thought: zygote = z-iGote), I may have Wendy’ed myself right out of the nursery (Peter Panreference), and (dare I say it) lost my knowledge of the younger generation (this may seem an impossible concept for most of the people around me, particularly your grandparents, who still don’t quite understand how I found a career that encourages my interests in cartoons and toys).

Read More:
http://metaversemodsquad.com/an-open-letter-to-my-future-child-who-doesnt-exist/

LOOKIE LOOKIE, WHO’S BLOGGIN’, COOKIE.

Ok, so more developments. In December of 2012, I finally took the much anticipated leap of joining my friends Amy Pritchard and Regine Weiner (amongst others, Mike, Rich, etc) at Metaverse Mod Squad.  For years, I had been a client and a friend to MMS… it only seemed natural to join in on the fun ;).

So, I’m now the Director of Digital Strategy & Engagement.  I really like titles that are a mouthful.  The longer the title, the more giddy I am.  The best part of this gig?  Instead of wrapping myself around ONE project, I now get to wrap myself around any number of projects!  I get to help many people – yay!  [sales pitch accomplished in a very covert way, now add the contact digits: izzy at metaverse mod squad dot com].

As for my beloved blog, which is growing to be quite the latch key pre-tween [epic fail, izzy]. I am happy to say that I’ve been part-time blogging for Metaverse Mod Squad’s blog (as seen in the quote above).  For a period of time, I stopped blogging here due to commitments elsewhere, followed by lack of content (or doubling up of rants).  We all know, I always have a rant shoved up my sleeve, but they’ve been in short bursts, and much more acceptable within the Twitterverse.

Overall, in regards to kid entertainment – I’ve not been impressed.  Movies have been “ok,” cartoons have been “ok” (exception: Adventure Time is amazing), live action shows have taken a turn downward, and the toys “over baked” or “over sexed” (what’s new there? le sigh).  Digitallly speaking – there’s definitely been a few highlights here and there.  Some interesting stuff on the horizon, but it’s a tough time for kid-based digital properties.  Even when awesome kid-based interactive experiences pop up, there seems to be low cash flow, or complete ignorance and misunderstanding on the high-exec level of what it means to have a kid/family based property (and how the monetary growth happens).

Sometimes I get weary of “pouring one out” for your fallen homies (RIP, my virtual world friends).  My bitter sweet sadness is temporary, I still have the faith!  I think we’re going to see an uptick in kid experiences in the next 2 years… I’m just waiting to get excited about something juicy & innovative & fun.

I will say – Youtube has DEFINITELY changed the game for digital entertainment & IP creation.  For the last year I’ve become obsessed with watching trends rise out of Youtube… and even when they’re “for teens” or “for adults” -> the early adopters tend to be the 9 – 12 year olds who find and share this content first.

Note: Kids in social apps are booming (and I’m not talking the apps created for kids).  The new social world for pre-tweens, tweens, and teens? Comments left in UGC (Vine, Instagram, Youtube comments, even comments on app rating pages in iTunes) – and don’t get me started on the smart phone tween empire… lawdy!

I have a bunch of rock star clients now, and I’m having fun playing in new playgrounds (general audience social media, large scale game companies, smart phone app strategy… you name it, we’re rockin’ it!).

Anyway – check out my blog post above for Metaverse Mod Squad!  You may see a bit more insight on where my brain is at these days (in regards to kids online).  🙂

xoxoxoxox I shall be back.

January 28, 2013 Leave a comment

I hope to see everyone at Digital Kids! My dearest friend Joi Podgorney will be emceeing a good portion of it (which is always fun to watch), and I’ll be hosting a panel on Wednesday. 🙂

In addition, we’re trying to think of a cool place to do “drinkie poos” (as my late/crazy Grandma Neis used to say) for socializing, hanging out, casually networking, etc. If anyone has any ideas or thoughts on such a place – comment in the comments below!

WHO IS GOING TO BE THERE? “You” better! 😉

Joi Podgorny

I am excited to be involved in this years Digital Kids Conference as an emcee for the first day’s talks.  It’s collocated with Toy Fair again in NYC, so we should have a nice crowd.  Tonda, Chris and crew are promoting on the regular social channels – Facebook, Twitter, etc.

There is also an affiliated Digital Kids Safety Summit as well – you know I’ll be THERE too.

In prep for the conference, I was interviewed about my predictions for our industry in 2013.  Here’s a snippet:

“The new COPPA articulations have changed the digital climate. COPPA requires a level of parental engagement and involvement that many families don’t realize. Parents don’t understand how much parental consent they have to give, and new online safety and privacy articulations are going play an important role in online parenting,”

You can see the whole interview here.

Hope…

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Categories: Izzy Neis Links

An Izzy-torial: ADD N Me

October 11, 2012 2 comments

So, recently I’ve been experiencing moments of mental “fubar”-ness.  There’s rhyme and there’s reason for it, and it goes well beyond what I chose to discuss today [there’s a time and place to discuss heartache, personal frustration, and bereavement – and its called ‘vague facebook statuses’ Lolzerbot].  But, I digress…

In my attempts to logically understand some of the chaos I’m trying to sort through in my brain, I’ve come back to a small nugget of a “disability” (and I use that term lightly, as it’s more of a “unique ability”) I’ve grown up with… and that’s what I’m going to dive a bit into. Oh bless cathartic posts.

If you have ADD (Attention Deficit Disorder), or a child with ADD, or a loved one with ADD… maybe what I will share will help you understand a bit of process or frustration they experience.  This is, of course, just my point of view… but you never quite know who may identify with it.

College photography “self portrait”.
There’s a whole lot of “god knows what” going on in that brain/expression.

I grew up with ADD (and no, against popular belief, NOT ADHD), and I probably still have some forms of adult ADD.  I do not conceptualize the knowledge around me the way that others might consider “normal” (case in point – the phrasing of that statement), or in a way that the greater populous might understand/identify with.

“Nobody realizes that some people expend tremendous energy merely to be normal.” – Alber Camus

Before I was diagnosed at age 10 with ADD, I was “not correct”.  Weird statement, right?  Lemme explain: I didn’t hear things the way they were meant to be, I didn’t understand directions the way they were given, and I didn’t complete tasks the way they were required.  Not on purpose, mind you.  You know the phrase “reading between the lines” – it was as if I’d read all the wrong parts, heard non-existent intentions, created context unsaid, and imagined another method for an end result (an end result of my own determination).  None of these were consciously chosen.

It was very difficult trying SO HARD to be a good student, a good child, a good person when my interpretations were SO far off.  Which goes back to – I was incorrect.  I’d go as far to say – I was incorrect about 65% – 75% of the time.  Not very good odds, and very hard on a mushy child’s brain in the middle of “formation”.  And I haven’t even introduced the fact that I was a stubborn force-to-be-reckoned-with, if not “passionate” child.

The “less awesome” things I learned (or adapted to) from having ADD (tough to swallow for the aforementioned child):

  • Never immediately trust my (first) instincts,
  • The majority of the world is “correct”, and I am not ,
  • “At least my failure is well-intentioned”,
  • With context and lots of over-explaining, I too can curb my understanding to eventually match everyone else’s!

When I was diagnosed with ADD – it was a bit of a god send.  I wasn’t stupid, and I wasn’t lazy (as were mentioned by some twit-teachers).  I had something to cling to – an explanation, a CONTEXT of why I wasn’t “correct”.  We started seeking alternative methods to help support my learning disability – finding my strengths in the play patterns I naturally gravitated to — STORIES.  Me and my world-o-Barbie?  Oh man, no Soap Opera could have EVER compared to the epic, dynamic events that I created in my own wee little world.

Nothing was EVER so powerful as the opportunity for fantastical creation by an imaginative child grasping at “reality” straws.  

I made my rules, I made the logic, I got to play GOD and I learned what it felt to be CORRECT. Yay for self-contrived self-confidence! (Lol, sure, but its true).  Additionally, writing provided me an opportunity to appeal to others with context, emotion, and creative expression – I discovered the existence and the magic of possibility through another perspective. WHAT? Two people can be correct but with different statements? <- strangely, this is a foreign concept to SOME children who end up having to go by structure and set-statements made by others because they were always made to feel inferior, stupid, or incorrect.

It wasn’t until I started taking my creative writing in college seriously that my soul blossomed and life started to FIT.  With a little creative logic, I was able to give context and structure to the things in life I was misunderstanding or failing.  With story – it was no longer “memorize this word because everyone else understands it”, but facts and information became tools within a larger story that formed a general understanding – one that I created and could identify with (or “understand”).

Things I learned that benefited me long-term:

  • Imagination is so powerful in the entertainment world (occupationally speaking, lol)
  • Self-deprecation & humor
  • The ability to apologize & accept responsibility (this is actually a fault too, as I’m quick to appeal for an apology for things I shouldn’t apologize for… but I prefer to assume responsibility myself, then be accused)
  • Mediation (beyond people, but mediation of differing concepts)
  • Reading people and treating judgements carefully
  • “There’s always another way” – one door closes, there’s probably 12 more down the hallway (if you will).
  • Question. Everything. But respect the populous for their structure.
  • EMPATHY EMPATHY EMPATHY

The strange result of me HAVING ADD, and me ADAPTING my ADD to the world is that I approach everything with 2 reactions.  This can be very tiring, and at times like a thunderstorm of frustration internally.  Occasionally one perspective comes swiftly – like a locomotive train, full of tunnel-vision and speedy determination (and if proven wrong… the subsequent reaction is just as powerful with spiraling questions and epic self-doubt), while the other moseys through the devil’s advocate debate of context and understanding like a Sesame Street skit of silly, imaginative rationals [this is near, this is far. Near. Far.  See it?].  Also, when the spotlight is on and your knowledge is questions – there’s a certain measure of insecurity and defensiveness that can come through — but that’s not too far off from how the majority of the world feels, I know.  The difference is… growing up with ADD, you already know that you’ve been proven to be “wrong”, and you know the world knows you have a greater % of actually successfully being accused as such.  Sure that definition of “wrong” changed over the years to a “unique perspective” (empowerment) – but there are times you can never shake that 3rd grade F because you misunderstood the question or the directions.

I’m thankful for a great many things that ADD empowered me with — as it was a fault that increased my talents.  But learning how to “overcome” is much like “success” – it’s a path, a roving goal, and rarely a destination.  So, maybe I don’t have adult ADD, and maybe I’ve learned how to adapt to certain things in life… but that doesn’t mean that events from childhood ever truly go away.  Every action has a change for thousands of reactions… some you don’t see right away, and some you live with every time your feet get nailed to the floor.

Find outlets, support each other, be empathetic, be certain, and be creative – and help others do the same.  I think I have to learn a bit more about self-forgiveness, and I would encourage you to do the same for your child who may or may not have ADD.  There’s no better way to end a post like this then with one of the BEST quotes of all time, from my person deity – Jim Henson:

“Watch out for each other. Love everyone and forgive everyone, including yourself. Forgive your anger. Forgive your guilt. Your shame. Your sadness. Embrace and open up your love, your joy, your truth, and most especially your heart.”

Fightin Monsters

May 22, 2012 1 comment

No, not another rant.  Taking a deep breath after that Muppet/Bachelorette tirade I just finished off.  It’s never good to shake a finger at a Big Dog in the industry; however, to quote Leslie Knope (Parks & Recreation on NBC): “If I seem too passionate, it’s because I care. If I come on strong, it’s because I feel strongly. And if I push too hard, it’s because things aren’t moving fast enough.” lol.

Anyway, on to brighter rambles: I thought I’d give ya’ll the heads up (and make it known in blog-form) that I recently joined the team at FightMyMonster.com, and I’m getting back to my hands-on community-roots.  I had missed the gaming side of the industry.  I love this demographic (tween boys) & general concept/direction (monsters & strategy).  As always, there’s a fair share of work to do (again, tween boys are never dull in community/behavior management), but I’m jazzed about it & ready for it (<cracks knuckles>), and the team is awesome (high five to Dylan & Dominic, et all).

With all the due respect in the world for previous employers and contractors, this is the first time I’ve walked into a company that’s already crossed the 1 million user mark BEFORE my arrival on less than a year lifespan & a skeleton crew.  And it turns a profit? What?  Yes.  I’m very impressed with the folks here, and psyched to see what mischief we can get up to in the name of awesome entertainment.

In my tenure, I’ve worked with Virtual Worlds, interactive websites for cartoons/books, MMOs for kids AND adults, and social networks for kids… and now I’ve got interactive strategy game too.  It’s a simple site concept, but boys just EAT it up.  I’ve never seen anything like it.

I’m excited to see what this company brings – both in entertainment shenanigans and life/career lessons.  😀

OH – and by joining this team, I also made a career goal: I was mentioned in a post by Kidscreen (squeeeeee!):

http://kidscreen.com/2012/04/24/fight-my-monster-hires-user-engagement-vp/

Other things for you to check out:

http://corp.fightmymonster.com/

http://twitter.com/fightmymonster 

Categories: Izzy Neis Links

Dear Parents: Help me help you. Help ME. Help YOU.

September 30, 2011 1 comment

So, there’s a LOT of interesting conversation happening lately… or at least I think it’s interesting (lol).

  1. About COPPA, future plans to COPPA, adherence to COPPA, and the FTC’s role in supporting COPPA.
  2. Cyberbullying & Cybersex (from the small to medium to high level interactions)
  3. Site responsibility vs Parent responsibility.

#3 is more or less a conversation that @JoiPod (Joi Podgorny) and I continually have as we develop methods to service our sensitive, bright, clever audience, and their parents (adjectives pending context of situation).

There are TWO ways of approaching the above topics: A) As theory & Industry conversation, B) In practice & actuality.

It’s great to come together and talk about how WE – as adults, participants in youth culture online, responsible citizens, and concerned governing bodies- can build opportunities to help kids succeed.  I will ALWAYS be up for that movement / discussion. 🙂

And yet, during my tenure within this industry and all the varieties of platforms I’ve worked with – I have started to recognize a growing movement of response and expectations for responsibility.

And so, I’m going to point my bloggin’ ranty finger at this growing movement.  Fair warning, I weave in and out of all sorts of open issues regarding kids online, beyond just COPPA, and often bleed many ideals together (because when you are in the market of “practice”, it’s either you can or can’t…, and that transcends what is defined in the ‘law’, and often leads to the variety of expectations and public assumptions).

Picture this:

Instead of Superman dressing himself as Clark Kent everyday (in his ongoing efforts to protect his identity), now dozens of

Clark, close your shirt... your Superman is showing!

invisible moderators frantically attend to Superman with a mission to keep his secret safe, and a dozen invisible moderation floating through the air, shielding & blocking the public’s vision of Superman (ya know… just in case he’s forgetful or makes a mistake).

COPPA is the only legislation available to protect kids – and it’s centered around identity – NOT appropriate content.

I have always believed that if you HOUSE a site, you have responsibility for maintaining the integrity and safety for that site too. That being said:

  • Is individual identity/safety becoming a community responsibility more so than personal responsibility?
  • Is it the community’s ultimate responsibility to stop your child from inappropriately engaging another child?

Identity is huge, and kids need to protect themselves as much as sites are expected to.  With COPPA – we know that personally identifiable information CANNOT be shared without parental approval.  Ok… so that’s step one, but you and I both know, that is NOT the only expectation out there, and nor sure it be.

Extreme cyberbullying often happens when real identities are exposed online (whether usernames are shared offline or real names/contact information shared online).  It also exists with inappropriate language, or just simple rudeness (you’d be surprised how simple it is to bully someone with non-aggressive, non-obvious words).  So, now we have to be prepared for: privacy issues, cyberbullying, and explicit attempts at communication.  (I’m not complaining, mind you!)

If I (as a site operator) set up rules and tools and back-up policies… and a child STILL tests the system with work-arounds – how far down the line will sites be held responsible for rule-breakers?  Best policy suggests actions to the account (suspension or ban, access loss to features, etc), and best policy suggests that sites notify, learn, and improve systems.

Cyber-education is available ACROSS the net (there’s maybe a couple hundred organizations dedicated to cyberbullying awareness on Twitter alone).  Here’s my question: when does the public’s engagement with cyber-education happen?  When should it happen?  And why does it feel like cyber-education only receives attention when negative things happen?

Ultimately – there is a growing need for responsibility to be taken within the home – and responsibility to be explained to the child.  How do we help educate and involve all the parties (like families, schools, extended families, friends, individuals) WITHOUT having to change a website’s business-model?

This has been an open conversation for a LONG time now, and it’s a rather sensitive topic as NO ADULT who loves his/her child wants to be called out for a possible issue or failure (failure being a rather strong word, my apologies).

Our industry’s endless enigma: How to involve parents who don’t have time to be involved.

Not all garbage comes in a can... It's your business to secure your CRAP 😉 ("Check yourself before you wreck yourself" - Ice Cube)

Look – please don’t shoot the messenger here, Parents.  Momma Bear has claws and Poppa Bear bites… I know that (I was a ref for toddler soccer for 2 years in college… if you have EVER been a ref or a coach – you know what I’m referring to here).  I respect the amount parents have on their plate!  That being said, I ask you to talk to ANYONE who deals with kids online, and you’ll get the same response… the majority of parents only involved if something negative happens (and then it’s typically an aggressive conversation of blame with the site).

My fear: Does this mean that the government has to step in and point a greater finger of responsibility to sites?  Is that what will happen with the expectations of a new COPPA?  States are adding new Cyberbullying rules – are those rules going to bleed into COPPA, and therefore introduce new enforcement responsibilities or expectations on sites?

I know parents need help, they can’t possibly have eyes EVERYWHERE.  Most of us in the industry want parents to expect nothing but happiness and rainbows and fun and friends, etc, within our kids websites/games.  Safety reassurance is almost always a part of the business model.  And industry people like me?  WE ARE TRYING EVERY SINGLE DAY TO PROTECT YOUR KIDS, and often succeeding.  However, new slang happens by the moment, and a minxy tween exploring language/sexuality/peer competition, etc, will do what they need to in order to surpass the mandated boundaries blocking them from their goal.

The more blocks, the higher the frustration, the more determination to get a result.  Such actions = more pressure on a business, and more money spent on scaling/tools, and a greater difficulty for success which affects the audience, business, and general site entertainment.  Let me reiterate another way:

  1. The more obstacles put on a business directed to children now will result in…
  2. A decrease in businesses directed to children later while will result in…
  3. More young kids involved in 13+/adult sites that do not have “Best practices” or “Good policy” or even “COPPA”.

We know there are a GREAT amount of kids who lied about their age to join sites like Facebook, Formspring, Foursquare (with their fancy smartphones), and Twitter.

So, as COPPA gets its make-over, and as this nation of helicopter parents grows, and kids make privacy/identity mistakes or keep attempting boneheaded social interactions… how do we aim for online success for youth without building landmines & sinking traps?

Help me, help you?  Help me, help you…. Seriously.  Let’s tackle this together.

How about instead of "Show me the money!" we go with "Show me the united front for taking responsibility in protecting and educating kids across the net!" ...What, not catchy? Oh, Beans.

Add your thoughts at the beep… be they charged, devil’s advocate, sympathetic, or requesting more context.  I’m really interested in this as an exploration conversation.  

Categories: Izzy Neis Links

It’s Arrived! FTC’s Proposals for COPPA amendments

September 15, 2011 1 comment

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

The Federal Trade Commission is seeking public comment on proposed amendments to the Children’s Online Privacy Protection Rule, which gives parents control over what personal information websites may collect from children under 13. The FTC proposes these amendments to ensure that the Rule continues to protect children’s privacy, as mandated by Congress, as online technologies evolve. The Commission proposes modifications to the Rule in five areas: definitions, including the definitions of “personal information” and “collection,” parental notice, parental consent mechanisms, confidentiality and security of children’s personal information, and the role of self-regulatory “safe harbor” programs.

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

Wow… so, after a year of research and reflection from the COPPA round table in DC, the FTC has come forward with some proposals / amendments to the Children’s Online Privacy Protection Act.  This should be VERY interesting, considering the upcoming push for kids to participate in Social Media platforms (*cough* Hearsay… Facebook *cough).  Take a look at the link above for full run down from the FTC website. Otherwise, here’s a quick bullet list.

Proposed changes include, my notes in RED:

  •  Updating the definition of “personal information” to include geolocation and persistent identifiers such as tracking cookies for behavioral advertising. (Wow. I actually think this is GREAT for all those platforms now collecting location.  Seems like a no brainer in regards to children.  As for Behavioral Advertising?  Man oh man, this should be an interesting shake-down.)
  • Modifying the definition of “collection” to allow children to participate in interactive communities without parental consent. (Sites must employ reasonable measures to delete all or virtually all children’s personal information before it is made public) (I’m not sure how different this is from what is already practiced?  I will need to do a deeper dive to understand what this is in exact reference to, or what this actually affects – if anything at all).
  • Streamlining/clarifying information that websites give parents prior to collecting children’s personal information (adding more information in the notifications, and not hiding in only in the Privacy Policy) (This is great in “theory” – but let’s be honest… it’s hard enough to get parents to see the BIG GREEN CLICK HERE / URL at the TOP of a welcome email, regardless of the information buried within the email.  I feel this is a “good policy” amendment more than something that will prove helpful, which is sad.)
  • New Parental Verification / consent opportunities (Yay! we need new methods!):
  1. Electronic scans of signed parental consent forms (The modern “fax”, lol.  No brainer here.)
  2. Video-conferencing (Bwaha! Dear gawd almighty – this is BONKERS for scaling… Great for quick-fire Customer Service & Skype, nuts for staffing and sustaining large groups)
  3. Government-issued IDs checked against a database (note: promptly deleted after verification) (Interesting! Lots of “Big Brother”-esque thoughts stream through my head, and I don’t necessarily think its a bad thing in regards to children… But that’s because those actions help me do my job in protecting my audience).
  • PROPOSED DELETION OF EMAIL-PLUS (This is a HUGE FTC proposal. It could affect a LOT of businesses and platforms for kids. Seriously.  Not to mention, marketing emails & virtual worlds… People who have been using email plus + great policy are about to lose a LOT of numbers in registrations!  Oooo doggy!)
  • New 180-day proposal for companies seeking “new” types of verification processes to be vetted and approved (or rejected) by the FTC
  • Safe Harbor programs must do annual audits. (Um. Yeah. I feel like there should be biannual audits done, but in a cooperative, friendly manner.)
Overall – interesting day of information.  Commenting has started on these proposed amendments… so get on it if you feel the need to speak out.  The only yellow flag for me = deletion of Email Plus.  It has been the EASIEST method to engage kids… and the lowest barrier to entry for parents (*no comment on the easy work arounds).  I worry that this will just send kids tenfold into adult areas or into opportunities of lying to get what they want.  Overall, maybe it will be a great thing?  I think I’m just foreseeing the crunch various companies are going to have between removing the “email plus” approval system and entering the “full verification” method.  I know a lot of companies have used email plus in a positive method – with extensive filters, moderation systems/practices, and staffing.
So… what do you think?

Engage! Expo Conference Prezzie

September 27, 2010 1 comment

Hello, hello. Long time no talk. Yes, I realize this, and I send my apologies.

Last week (Sept 22nd), I spoke at the Engage! Expo conference in Santa Clara on User Engagement – aka, the art of engaging users (specifically online gamers 13 and younger, although you could argue for a General rating).  It wasn’t one of my most stellar performances, I drown a bit in having FAR too much to say… but I successfully rambled a few decent points & tales, and hopefully shared some new understandings as well.

I am always grateful to the Engage! Expo team (Tonda you’re amazing), and it was great meeting some new people.

Now, prepare yourself for some Heavy. Duty. Slide. Action.  I Powerpointed it up HARD CORE (my speech teacher would be throwing ninja stars at me if he knew).  Luckily, many people have contacted me asking for my Powerpoint slides… so, I am providing a video of them here.

Questions, comments, problems, scenarios, rambles, quips, complaints, queries, and soliloquies should be directed to the comment section of this post.  I’ll do my best to get back to you.

Things I’m kickin’ myself for leaving out: Monetization and the “velvet rope”, How to use live staff well,  the Parental Unit, and The fine art of event planning and support.  Thank god there’s always future conferences – I can do a “Part Two” slide set 😉

Is there such thing as 100% Safe Chat for kids?

June 28, 2010 6 comments

My oh my, ain’t this the question of the hour.  I’m definitely not going to win any friends from some people on this one, but folks – I’m not going to B.S. you here.  There are people who philosophize laws and legislation based on all sorts of elements, there are people who make tools, there are people who are charged with helping, there are people who research theories, there are people who spend efforts for education or overzealous protection, there are people who have propoganda & agendas (good-good, bad-good, good-bad, bad-bad), and then there are the people who just gotta get the job done: every. single. day.

There are a lot of people in the pot trying to decide what “safety” means these days – especially regarding chat.  I’m just gonna tell you a bit of insight from my side, the “every. single. day” perspective – think of it as the stage manager telling you what’s happening behind the curtain, but also knowing what is expected to be seen by those in front of the curtain.  It’s a very different view from the director, or set designer, or critic, or actor, or audience…

Here are a bunch of questions I get:

1. What are the safeguards for chat for kids? (aka, what are “filters”)

As we know (or as you’re now learning), registration processes aren’t the only method of PII collection (PII: personally identifiable information – which is prohibited from being shared by children under the age of 13 through the legislation called COPPA).  In these virtual experiences like MMOs and Virtual Worlds and Chat Clients and Social Networks – there are a thousand ways to share information.  People put in “filters” that are trained to catch or allow content, based on the type of filter it is, so that content can or cannot appear within a social space…

  • Dictionary Phrase list – basically a list of predetermined statements with no room for alteration
    Pro: Your users cannot alter or break any of your systems, unless they’ve figured some alterations ultra-serious language using codes of first initials to sentences, lol
    Con: Really, really, really frustrating. Really frustrating.  Not a great user experience because everything is dictated, and unless it’s a GINORMOUS list of pre-determined statements, there is little room for off-the-cuff roleplay, and being dictated to is never something a pre-teen/tween child likes…
  • Dictionary lists – basically a list of all permitted words – like an uber list straight from the dictionary (lol – hence the clever name)
    – Pro: You’re only allowing certain words and blocking out any phonetic work arounds or garbled attempts of spelling (ex: words like funkyou or asstronaut are not in the dictionary and therefore caught in the filter before appearing live).
    – Con: Dictionary lists are HUGE. Let me repeat HUGE. You better scan through them for medical terms like “pubic” or “pedophilia” both of which are in the dictionary, as are “address” and “phone” and “email”.  Also – phrases are not in the dictionary – such as “as hole” or “read hard dead” or “name at yahoo dot com” and “my house is on third street maytown illinios”.  Heck, you can even use work arounds like “my digits are ate hero hero tree tree fort hive sicks mine on” (that says 800-334-5691 which is a number i just made up using the types of easy work arounds KIDS USE EVERY SINGLE DAY – no. joke.  All words in the dictionary).  Also – with every user who creates a new username – there is yet another addition to your white list.  Kids have to be able to speak to each other, right?  1,000,000 users = 1,000,000 additions to the dictionary… YOUR CHAT PROGRAM IS GOING TO BE VERY, VERY SLOW.
  • White list – An extensive list of appropriate words (and some phrases) that your team has specifically allowed in chat (much like the dictionary chat).  Typically, must have a smaller blacklist to balance out some of the issues.
    – Pro: You’re starting with a set list of approved words and statements, you have a little more control over the types of conversations you wish your users to have.
    – Con: Young users with issues spelling will never get to say what they’re trying to say unless you have the foresight or capability to see what they’re attempting to say and add to the white list.  You have a smaller range of free community unless you’re actively keeping up with the chat of kids and making new allowances, etc.  Also – good luck with symbols, characters, punctuation, and numbers – since your system has already chosen the words it likes, kids can use these other things to break what you’ve set up.  Youre mini black list better be prepared for statements like “silky fingers” or “hard purple staff” or “up your skirt” or “chocolate kid” or “lets have sax”
  • Black List – An extensive list of inappropriate words/phrases blocked from chat, with a subsequent white list that helps balance out the black list for appropriate content.
    – Pro
    : It’s an active list that is monitored, changed, and edited by the day to support the growing needs and cleverness of youth & pop culture in general (which can also be considered a con, lol).  You know exactly what they cannot say, and removing all negative content is the emphasis while trying to be clever enough to not break the user experience (as we know, inappropriate content changes by the day – thank you South Park and Family Guy). Urbandictionary.com is a great help.  You can prepare the blacklist to look for such phrases as “my addy is” or “real name” or “in your pants”)
    – Con: Unless you have a tool set that can separate words, find gem-of-words within bigger cluster-words, ignore run-on vowels or extra characters, read thru spaces and numbers and symbols, etc, well…  you’re going to have problems (and there ARE tools out there that do this… you just have to look, test, research, etc).  This is what I call “control over your active road map” – you need to be working to verify that all options around and through your blacklist controls are sticking tight.  Example: the word “ass” is inappropriate, but can be said in “class” and “assembly”… make sure it’s not caught.  On the flip side, the work “retard” is never appropriate in any variation – so the filter needs to be able to catch “uretard” or “retardation” or “ret@rd” or “r3t@rd” or “mrretardkid” < all of which I’ve seen kids attempt.  Also – this is not something just anyone can pick up… knowing how to work and manage a black list effectively is a solid job and needs care & cleverness.

2. Can I be 100% certain my chat system is safe from PII collection or sharing by children?

NO.  Not unless everything is pre-screened before going live (example: the phrase dictionary or canned chat alternatives).  And even if you had moderators screening all content before it goes live – that is a heavy scaling issue, with a lot of room for human error.

I’ve already mentioned the types of identifiable location words that need to be removed in Dictionary Chat / White list / Black list.  But what I haven’t mentioned are first name / last names.  Unless you restrict first names completely (including a user’s avatar name), you’re already in the hole.  Why?  I don’t know about you – but just because someone once told me not to date guys with two first names doesn’t mean they don’t exist (teasing about the two first names… clearly that’s just a myth… hehehe).  Ryan Edwards. Tiffany Addam.  Joe Gail.  Larry Drake. Then you have the first name + object last name, such as Jack Hall, Charlie Brown, Jerry Trainer, Sally Stir.   There’s not a chat list in the world that’s going to block that unless it’s prescripted.

On the flip side, you also have numbers (should always be removed from even TYPING a number on a keyboard – why give what they can’t even have?), symbols should be removed (there is no need for @ or > – smilies are what emotes are for), and really the only punctuation should be the exclamation point and the question mark.  Even THEN you’re going to see abuse for PII sakes… “My digits are ! !!!!!!!! nil nil !!!! !!!!! !!!!! ! !! !!!! !!!!!” and there’s an 800 phone number.   Or the progression in chat for this:
“my digits are after the a. write em down. A!!!!!!!!” “A nil a nill” “A!!!!” “A!!!!!” “A!” “A!!!!” “A!!!” “A!!!!!!!!!!”  Again, prescripted might help stop this.

Now… here’s the thing about prescripted agendas.  YOU LIMIT A KID IN A WORLD WHERE THEY’RE EXPECTED TO FORM A COMMUNITY – AND THEY’RE NOT GOING TO STICK AROUND.  Sure, if the game is fun, they’ll play the game, maybe stick around for a session or two… but why even make it a social game? YOU CAN’T BE SOCIAL IF YOU CAN’T BE SOCIAL.  And, heck, kids are just going to fire up their aim and/or gchat and/or msn and/or text messages.  At least with the filters and time/effort you were putting it… you were doing YOUR job in trying to protect them.  Put massive restrictions on chat and lose the social experience for users to some other techniques that are less capable / less responsible to do the job YOU could be doing the right way.

Which leads me back to – WHY MAKE A SOCIAL EXPERIENCE GAME? I’ve only seen Poptropica.com do this well – and they’re not really going for a social community.  They’re going for game-based/story-based interactive, educational fun without community or self-expression or role play… it’s about the agenda decided for the purpose of the game.

But how do we protect / stop users from these simple methods of info sharing – like first name + last name?  Put it in your rules, your Terms of Service.  Inform the users, and the parents, that there could be a chance that something is shared by accident… and that your site will remove any/every user who breaks this rule.  Put forth the best effort with filters and POST MODERATION (various ad hoc methods that illuminate users who are breaking the policies you’ve set).  If they can’t play by the rules and regulations you’ve set, and if a user is putting your brand/game at risk… SO LONG, GOOD RIDDANCE.

The only way we can REALLY attack this problem is through education.  Either in-game, pre-game, parental education & guidance… but for me, I’d like to see POP CULTURE EDUCATION.  Ad campaigns, commercials, etc.

And by the way… these are only a *few* of the examples there are in work-arounds.  There are MANY, MANY more, and they change, grow, mutate by the day.

3. What is the safety method of chat filtration?

The safest method is whatever you know works the best for YOU.  There’s no “one” perfect situation for every company, every philosophy, every policy.  Look at what your variables are:

  • Who is your target user (and what might he/she say around the lunch table with friends), who is your secondary target, and who is going to show up unwanted at the party…
  • What is the type of content/genre/fantasy you’re building, and how will the language that corresponds with that effect or change the typical every day language scene (example: if you have a world where everyone is an ice cream flavor – being called vanilla kid or chocolate kid doesn’t have the same context as it does in an athletic world where kids are sassing each other)
  • Who is in charge of policing your policy in your world – do they understand the type of content that needs to be caught?
  • Do you/your team have a sufficient enough understanding of language / pop culture / kid behaviors / online minxiness to be able to properly control / handle what you want for your audience?
  • Do you want to control your language road map – or do you wish for the aid of another company to control the language?
  • Do you understand what legally CANNOT be shared in chat?  Do you feel you have sufficiently restricted the public sharing of PII?
  • How do you want filtration to appear to the end-user?
    – Do you want them to be warned for certain language?
    – Do you want to put certain words in black boxes, where only the author can see it and the rest of the social room cannot?
    – Do you even want kids to know what words they can/cannot say?
  • How are you going to know when kids are creating language work-arounds?
  • If you allow a vendor to control your language lists, who carries the responsibility/burden if the list is not sufficient? (are you QA-ing your own policies / site?)
  • How are you going to react to users who are breaking your policies regarding chat?
  • Have you removed / scrubbed any content accidentally provided by users?

I have what works for me, and for now I’m very happy with my method.  Naturally – I am always looking / learning / finding new ways of improvement for policy, implementation, experience, etc.  That’s my job.  At the end of the day, I am accountable for the users and the company. Not only is there legislation, there is a sensitive and young audience involved.

This all leads to the “what next” step of COPPA and the recent COPPA round table that happened at the start of June.  To be honest – I’m scared.  I’m scared because there are a lot of different ideologies floating around regarding PII and chat.  The fact conversations are happening isn’t what scare me – it’s the lack of hands-on knowledge from people who have to do this every day (and I’m not talking about the directors or managers who haven’t even once signed into their tool set – trust me, there are a few of those out there).

There seems to be a lot of people looking at what’s working for others and trying to do the same… but no two sites, no two games, no two companies work the same.  Chat always seems to be one of the LAST thoughts for people… not that it needs to exist – but HOW, and what the experience is like for the end-user.  Font, character allowance, timing, content – it’s essential and standard and needs to be treated in design and creation with the same respect as EVERYTHING important to the agenda of the site.

I’d like to see more people close their doors, Willa Wonka style, and figure it out for themselves – so they can speak to it and cop to it, etc.  I, for one, should not know your chat filter holes better than you do….

Categories: Izzy Neis Links

Let’s Chat: COPPA

April 25, 2010 5 comments

Twitter. I promised a rant on twitter. I promised a rant due on Thurs. It’s Sunday.

My apologies for the lateness and the possible lack of DRAGON FIRE that I was spittin’ on Thursday.  Indeed I was angry, and it had to do with weird (if not troubling and disappointing) rumors spread about COPPA.  But like the fear-mongering such rumors create – a tantrum is not what is needed here either. Clarity is what is needed.

So, my dear poppets – lemme share the facts about COPPA: Past, Present, and Future…

PAST

COPPA is the only “real” legislation we have to enforce/protect children under the age of 13.  COPPA stands for: Children’s Online Privacy Protection Act.  It was created to stop marketers from collecting and exploiting personally identifiable information from children.  What is personally identifiable information (or PII)?

First name / last name, phone number, email address, social security number, home address.

It’s also to good to consider the following PII:

School name, instant message clients, usernames for other sites, sister/brother/parents/teacher full names, zip code, small town + states, after school activity locations. – These are not held as stringently as the first group, but they’re equally as important since you can locate any child regarding this information. Basically: if I can find you easily with the info you provide… that could be argued as PII.

Remember this tip for the kiddies and yourself: Tangible/Open Air (non computer) life = Clark Kent, Online life = Superman.

COPPA is upheld by the FTC, who regularly posts announcements on their page: http://www.ftc.gov/.  There is a program governed by the FTC called “Safe Harbor”, and it is upheld by four organizations (CARU, ESRB, TRUSTe, Privo).  If you wish to be a part of the Safe Harbor program – you will get aid in meeting regulations, suggestions for “going beyond” and being better than bare minimum, and you will have legal representation if your compliance comes into question.  I have had the privilege to work with CARU and the ESRB (whom I am very happy to work with now), and I know the fine folks at Privo.  I would definitely suggest that any company or individual wishing to learn more about Safe Harbor reach out to these companies.

At one point they tried to make additional legislation: COPA (Children’s Online Protection Act) and DOPA (Deleting Online Predators Act) – both of which have been dismissed due to First Amendment (COPA) and sheer impossibility due to variables (the latter).

PRESENT

How is COPPA being used?  Well, no longer just a deterrent for Marketers, it is the sole legislation for anyone collecting any information regarding children under 13. But why would someone need to collect info from kids?

1. Newsletters
2. Registration for games
3. submitted in conversation (chat), pictures, audio, etc (basically – UGC, “User Generated Content”)

I exist in the epicenter of business, safety, entertainment, common sense, community, and I’m telling you… there is no real arguable reason to collect PII from children.  The decision regarding the sharing of any such PII information belongs to the parents. Ahh, now there’s the rub – how do parents make/enact/provide/receive that permission?? Lemme get to that in a sec.

What I forgot to mention in the “Past” section is that – COPPA legislation pinpoints 4 acceptable ways to gain PERMISSION to collect PII: a fax with a parents signature, valid credit card, phone call acceptance, and email-plus.  Naturally there are problems with all four methods.

  • Fax = expensive, not “earth” friendly, and who really owns a fax anymore? Not to mention – kids attempt to sign and fax themselves (the wily things they are). You lose more customers than you gain when you expect them to stop at KINKOS to fax something out – too much time, so long future customer.
  • Valid Credit Card = No one wants to put their digits in (and they had the 1 dollar charge, despite the fact we dismiss the charge), kids as young as 9 are toting their parent’s credit cards, it’s an opportunity to collect PII inadvertently from a child (AGE GATE MEMBERSHIP, pls), and kids have been known to take the card from mom’s purse (the cheeky things they are). Strangely enough – for parents who do not have any intention on purchasing a membership – they don’t really want to put in any CC information. Do I blame them?  Nope.  Too many “but what if my kid can access my number” or “But I don’t want to tricked into paying” or “Ugh, I have stuff to do. Dinner is almost ready. I don’t want to do this now, let’s go eat.”  deterrent!
  • Phone Call Acceptance = Heavy lifting on the part of CS, expensive call services, and how do you determine an adult’s voice if the adult happens to be squeaky?  Or a child who has low tones?  And, kids attempt to call in pretending to be parents (the sneaky things the are). One of the easier methods “in theory” – parents can just pick up and dial and say “yes” or whatever. No biggie. Except that – parents can’t make those phone calls if they’re at work, and sadly, from what I’ve heard, more kids call in than actual parents.
  • Email Plus = The least rigid, most used, least reliable method.  You request the parent’s email during the kid registration, you send a “Welcome” email that includes a click-through link that will open up UGC possibilities, the adult visits the link and chooses to allow or not allow UGC, and 24 hours later the parent gets another email reminding them that they did this (in case kids invade the family email, they will be caught “unawares” by the follow-up – or at least that’s the theory). The problem is that – a certain percentage of kids are putting their own email into the Parent Email slot, and trump the whole parent connection.

Personally, I lean towards Email Plus as a method these days.  As I said – I’m in the epicenter of a lot of needs.  My first and foremost goal is: SAFETY, followed by ENTERTAINMENT (kid style), and then the business, etc.  Granted Email Plus isn’t the “safest” – but that’s why I have POLICY AND PROCEDURE. I have moderation toolsets and staff, and, well me (cue chip on shoulder, my apologies).  We work behind the scenes during the live existence of the game to ensure that privacy remains active, despite the audience themselves. AND TRUST – this ain’t no walk in the park.

Children DO NOT understand what they should / should not speak about, nor do they get (en masse, I’m talking about now) why they should / should not speak.  So… you can pretty much guarantee that kids will attempt to share SOMETHING – the way around collecting this is:

  • Pre-screening & scrubbing content,
  • Filters that block anything close to PII (heavy, heavy black lists, or CLEVER dictionary chat that also reads phrases),
  • Filters that jedi-mind-trick the user (have you tried chatting with another user in Club Penguin? Only like 25-30% of what you try to say actually shows up to the public – this lowers frustration from users while safety guarding them from the public),
  • Scripted chat (Poptropica is still uber-popular and there isn’t an ounce of open or filtered chat
  • Post-hoc moderation – LIVE 24/7 staff on the look out for kids who figured out “work arounds” (like toe tree fort hive stick stephen for two three four five six seven)
  • Reporting mechanisms for kids to pinpoint those who are cheating the system

You don’t have to have all of them… but it’s a big decision to make, and not lightly either. Get council (from someone not selling you a product, please).

Once I have my front-line and behind-the-scenes methods in place – my next goal is to make sure kids come in and play the game… that they’re active and enjoying it.  If I don’t have kids on my site, I have no audience: no money, no sustainability, no kids to protect, no job.  And where does that leave kids?  Instead of at Disney World with the families and the attention to detail and overpopulated staff, they’re at Six Flags with the gangs and high school peer pressure (seriously, have you BEEN to a Six Flags in the last ten years? What is up with that? Um, NO, I don’t want to watch fourteen year olds try to make babies while I’m in line to ride on Batman, thank you. And no, I didn’t bring my Latin Kings sweatshirt today, darn I don’t fit in).

I do not, not, not recommend “Email Plus” for who has no intention of truly backin’ up the LIVE safety on their site.

If you do not have valid parental sign off for your online experience: you cannot allow UGC of any kind unless it’s screened first by staff and scrubbed of possible PII.  That means: usernames, chat, forum threads, forum posts, blog comments, guest books, comment walls, upload pictures, upload video, upload audio.  Basically: anything a user can submit needs to go through filters and screening.  Anything considered PII needs to be scrubbed.

What’s good policy?  Well, even when you GET the “valid parental permission” – you still filter the content, and you still have staff moderating.  This is YOUR brand and YOUR audience.

BTW: If anyone comes to you and tells you that a toolset will solve all your problems and that it will replace human staff – you better get your warning flag up.  THEY’RE SELLING YOU. Gross.

THE FUTURE

So, about two months ago I had the EXTREME privilege to sit on a stage at the Engage! Expo conference in NYC with Phyllis Marcus.  Phyllis is from the FTC and had been commissioned to look into behaviors in virtual worlds.  She has an interesting report here regarding the behaviors that were found.

When I spoke with her – the majority of my questions were around: How, when, what.  This was just an initial peek for the FTC into behaviors, and much of what they found was from first time viewing.  We talked a fair bit about COPPA, and what was next for the FTC.

Both Congress (on April 29th) and the FTC (June 2nd roundtable) are re-examining safety and privacy – and what that means from their standpoint.  Okay, their standpoint… but what about OUR standpoint, what will that mean for us?

  1. COPPA HAS NOT CHANGED.
  2. Talks are beginning: People are looking to open up conversation, reassess, get feedback about COPPA
  3. If changes are made to any part of COPPA it will not be immediate
  4. If COPPA does receive some changes, adds, tweaks, deletes – it will have a “Goes into Effect” date
  5. If there is a “Goes into Effect” date – companies will have a GRACE PERIOD in which to react
  6. But most importantly: NOTHING HAS BEEN PUT INTO LAW YET.  And regardless of any rumors regarding: “So and so said this” or “I heard that the FTC has already decided” – etc.  Stop perpetuating rumor that scares others into reacting.

IF COPPA changes, it will probably change due to parent verification – either attempting to find better methods of verification or deleting old methods of verification considered ineffective.

This shouldn’t affect any LIST (be it black, white, etc) that you have on your site.  As long as kids who ARE NOT PARENT VERIFIED are set to default “Scripted Chat” (or pre-written chat) you’re fine.  DO NOT ALLOW KIDS TO CHAT (filters or no) WITHOUT VALID PARENT VERIFICATION.  How to do that? Talk to company offering the Safe Harbor program.  Lawyers know a lot – but they’re NOT workin’ on this side of the biz daily, and it’s basically they’re job to be paranoid about the law (not necessarily how kids are using it). With the exception of a handful (@steph3n , @amymms , @mikepink , Liisa Thomas – yes two i’s, and Jim Dunstan, etc), I’d be mindful.  Don’t overreact because of fear.  Be proactive in finding out how, why, when, what it means to address kids online, to collect information, and to safeguard kids online (people to follow: @annecollier , @joipod , @twizznerd , @amymms , @tlittleton , @larrymagid , @shapingyouth , @chasestraight to name just a small handful, there are many more).

You have the parent’s permission – now it’s about upholding that parent’s permission and your brand and the safety of your audience.  Robust chat filters are great – THERE IS NO ONE SINGLE COMPANY SELLING THE ONLY APPROVED LIST THAT FOLLOWS THE LAW.  If you hear that? That’s bullshit.  Straight up. Someone is scaring you into buying a product, and that just breaks my heart…

I would LOVE LOVE LOVE LOVE to get into a discourse about my hopes, intentions, and goals for our industry.  I have met some really amazing, dedicated, SMART people – and together we’re continually trying to improve.  But when people come in and say things to “sell”?  That. Just. Guts. Me.  I know I live in the country of capitalism… but that doesn’t mean I have to support it.

I’ve put a LOAD of information in here.  My apologies for a lengthy, not so cheeky, probably boring post.  But let’s be honest – I needed to ramble on this topic.  Clarity is good.  If you don’t believe me, or wish to dispute any claims I’ve made… please feel free to GOOGLE COPPA YOURSELF, and/or talk to lawyers AND safe harbor folks.  Heck, place some comments, questions at the beep and we can walk/talk through it together. 🙂