Spirited News and Observations and Opinions ...

[GoofGoof]

3. Disney is rolling out FP+ along with NextGen. A part of FP+ includes the ability to 'link' members of a party together. Linking Johnny Jr to Johnny Sr would be considered personally identifiable information. Under COPPA this would be a no-no if the parents do not give consent.

I know we talked about this topic a few pages back, but by linking your kids to yourself you are giving your parental consent for their info to be linked to yours. They would just have to restrict kids under 13 from having their own account not linked to an adult.

 

[Lil Fort]

I know we talked about this topic a few pages back, but by linking your kids to yourself you are giving your parental consent for their info to be linked to yours. They would just have to restrict kids under 13 from having their own account not linked to an adult.

The last part is the key:
Unless...
4. Disney is able to classify the linking of Johnny Jr and Johnny Sr's FP+ data as a part of their 'internal operations'.
If they can convince the 'powers that be' that linking Johnny Jr and Johnny Sr's data is an essential part of their 'internal operations' then no consent would be necessary.

 

[Darth Sidious]

Here are the thoughts on this that I have put together in my pretty little head:
1. According to COPPA: Without parental consent, personal information about a child younger than 13 may never be used or disclosed to contact a specific individual, including through behavioral advertising, to amass a profile on a specific individual, or for any other purpose.
2. The final amended COPPA Rule also adds a process allowing industry to seek formal approval to add permitted activities to the definition of support for internal operations.
3. Disney is rolling out FP+ along with NextGen. A part of FP+ includes the ability to 'link' members of a party together. Linking Johnny Jr to Johnny Sr would be considered personally identifiable information. Under COPPA this would be a no-no if the parents do not give consent.
Unless...
4. Disney is able to classify the linking of Johnny Jr and Johnny Sr's FP+ data as a part of their 'internal operations'.

That's my story and I'm stickin' to it! How did I do? Am I in the ballpark?

That is what I took from it all... if they justify linking Jr to Sr for something like FP+ then they can get through the loophole. Then you market to Sr since Sr is the one making the purchases for Jr. (while utilizing data from Jr because they were able to loophole COPPA)

 

[Lil Fort]

That is what I took from it all... if they justify linking Jr to Sr for something like FP+ then they can get through the loophole. Then you market to Sr since Sr is the one making the purchases for Jr.

Yeppers! Oh what a tangled web...

 

[Darth Sidious]

Just an additional thought... if @Lil Fort is correct on the loophole with FP+... it seems that the success of NextGen hinges on getting through that loophole. If they don't and they need to comply with COPPA via traditional methods, this becomes a bigger mess. Then I'd assume a lot of their envisioned profits via marketing data goes out the window. I doubt they will let it fail after spending $2B but it sure would complicate things.

 

[GoofGoof]

That is what I took from it all... if they justify linking Jr to Sr for something like FP+ then they can get through the loophole. Then you market to Sr since Sr is the one making the purchases for Jr. (while utilizing data from Jr because they were able to loophole COPPA)

So they use the data collected from the kids to market to mom and dad? I guess that makes sense, but I'm not going to be quick to buy a toy for my son based on an ad sent to me since he may never even see it. I would think that if the focus was marketing to kids they would have to have some way to reach the kids directly. I still have to think that marketing to kids would be secondary in this whole experiment. Adults are the buyers. Their info is still worth more IMHO.

On the linking kids to their parents, that already happens with every room reservation. When I booked my room they asked for my kids names and they already have their address since they have mine. They got their own room cards (without charging privileges). They were pretty happy with it.

 

[GoofGoof]

The last part is the key:
Unless...
4. Disney is able to classify the linking of Johnny Jr and Johnny Sr's FP+ data as a part of their 'internal operations'.
If they can convince the 'powers that be' that linking Johnny Jr and Johnny Sr's data is an essential part of their 'internal operations' then no consent would be necessary.

But they would also be restricted from selling the info to anyone. You can't claim it's for internal operations and then sell it externally. If this whole data mining project is only intended to result in data used by Disney then I think this makes perfect sense.

 

[Lil Fort]

So they use the data collected from the kids to market to mom and dad? I guess that makes sense, but I'm not going to be quick to buy a toy for my son based on an ad sent to me since he may never even see it. I would think that if the focus was marketing to kids they would have to have some way to reach the kids directly. I still have to think that marketing to kids would be secondary in this whole experiment. Adults are the buyers. Their info is still worth more IMHO.

On the linking kids to their parents, that already happens with every room reservation. When I booked my room they asked for my kids names and they already have their address since they have mine. They got their own room cards (without charging privileges). They were pretty happy with it.

Linking room reservations already falls under 'internal operations' but under COPPA, they wouldn't be able to use that information along with the information that they collect from the RFID devices without the loophole.

 

[GoofGoof]

Linking room reservations already falls under 'internal operations' but under COPPA, they wouldn't be able to use that information along with the information that they collect from the RFID devices without the loophole.

OK, I think I get it. So it's not the linking of the accounts that triggers an issue it's the collection of the data from the bracelets and what happens to the data after its collected. I still think that by claiming its collected for internal operations it would prevent Disney from selling the data. Isn't that rumored to be the primary source of profit from this?

 

[Darth Sidious]

OK, I think I get it. So it's not the linking of the accounts that triggers an issue it's the collection of the data from the bracelets and what happens to the data after its collected. I still think that by claiming its collected for internal operations it would prevent Disney from selling the data. Isn't that rumored to be the primary source of profit from this?

I would imagine that once in the loophole it allows them to collect the data. Then linking that to Sr lets the company utilize that data by selling Sr's info which includes what his kid likes.

 

[Lil Fort]

But they would also be restricted from selling the info to anyone. You can't claim it's for internal operations and then sell it externally. If this whole data mining project is only intended to result in data used by Disney then I think this makes perfect sense.

COPPA has never prohibited the selling of information collected from children to third parties. It simply requires the consent of an adult for anyone under the age of 13 for the website/company to collect the information in the first place and it requires them to identify the third party companies that they are engaged in business with. The responsible adult also has the right to ask the company to provide what information has been collected and with whom it has been shared.

ETA: Remove the need for consent and ta-da! The perfect marketing scheme.

 

[GoofGoof]

COPPA has never prohibited the selling of information collected from children to third parties. It simply requires the consent of an adult for anyone under the age of 13 for the website/company to collect the information in the first place and it requires them to identify the third party companies that they are engaged in business with. The responsible adult also has the right to ask the company to provide what information has been collected and with whom it has been shared.

ETA: Remove the need for consent and ta-da! The perfect marketing scheme.

What's the point of the law then. All you have to do is claim you are only using the data for internal purposes, get the exception and then you dont need consent and you are free to use the data however you see fit. Makes no sense.

Wouldn't it be easier to just get the parent's consent. The terms of use of FP+ could just say that by linking jr to you and booking FP+ for him you are consenting to his use of the system. Seems easier.

 

[Lil Fort]

What's the point of the law then. All you have to do is claim you are only using the data for internal purposes, get the exception and then you dont need consent and you are free to use the data however you see fit. Makes no sense.

I think that was the point that @WDW1974 was trying to make way back when he first mentioned the recent changes to COPPA. They do have to prove their need to someone, although it doesn't say to whom. All that Disney needs is the right beaurocrats in their pockets and they are off scott free.

Wouldn't it be easier to just get the parent's consent. The terms of use of FP+ could just say that by linking jr to you and booking FP+ for him you are consenting to his use of the system. Seems easier.

That would give them an 'opt out'. I don't think they want an 'opt out'. Then they can maximize profits.

 

[donaldtoo]

I've only been following the NextGen discussion on here and on a few other sites very loosely, but this thing just seems, to me anyway, to be setting itself up to be one of the biggest fiasco's in Disney history. Why does there seem to be such a disconnect all the way down the line in TWDC?!?! Could this REALLY be a real "Disney's Folly"?!?!

 

[Magenta Panther]

I've only been following the NextGen discussion on here and on a few other sites very loosely, but this thing just seems, to me anyway, to be setting itself up to be one of the biggest fiasco's in Disney history. Why does there seem to be such a disconnect all the way down the line in TWDC?!?! Could this REALLY be a real "Disney's Folly"?!?!

Sure as heck sounds like it to me.

 

[TP2000]

I think, other than this Spirit, you are the only one who has commented on the dude's presentation. Look, if this were a sales convention at a Ramada Inn in Delaware, I would have expected him to be dressed better ... and it was pretty obvious he was about as prepared for meeting/talking with the media as I am to do brain surgery on a fanboi.

Does Disney's top dogs (Iger and Staggs) sit back and think 'yeah, most of our guests at WDW are slobs so we need our execs to be more relatable?'' or is this just yet another example of how far the company has fallen. Every OLC/TDR 'suit' I encountered when visiting Tokyo had a polished/classy wardrobe and attitude, so different from what I see here.

Yeah, I just don't get it. Tokyo "suits" still wear actual suits in the parks there, while the Anaheim "suits" do sort of an upscale business casual look, with occasional sightings of sport coats and/or neckties. And the WDW "suits" are in a much different league, not even tucking their short-sleeve shirts in any more.

But senior executives announcing a Billion dollar program to the media on launch day? Nick Franklin, who like many of us won't ever be confused as a male model, was wearing slacks and a blue shirt, with his shirtsleeves turned up at the wrists. I picked up on it immediately, because it's just such a shleppy look. It's an acceptable look for cubicle work and going over the latest TPS reports before running to Subway for lunch. But an Executive Vice President launching a Billion dollar revolutionary consumer initiative? For that, it just looks slobby and like the guy doesn't care about his project or its customers.

I think what makes these guys think their lowered dress code standards are acceptable is because a legit genius like Steve Jobs used to appear on the stage of the Moscone Center wearing jeans and a turtleneck. But a Nick Franklin is no Steve Jobs, and he simply comes off looking like a guy from cubicle 520E about to make a Subway run for his buddies working on the TPS reports. Put a coat and tie on, man!

 

[threeyoda]

This seems to me like it could go three ways. The first is that it could flop and be shut down in the next few years, never to be heard of again... OR it could be successful, and, if successful, absolutely revolutionary in the theme park business. If this all works (guest like it, it produces more income, etc) I think it'll rapidly expand to Anaheim, Paris, Hong Kong, Tokyo, and I bet that Shanghai will open with nextgen pre-installed. Universal will probably roll out something similar too, I bet that they're watching this closely to see if it goes well. Eventually, I could see variations of this trickle down to SeaWorld, Busch Gardens, Six Flags and Cedar Fair parks too. Imagine the possibilities at SeaWorld with their animal shows! This could easily change theme parks if successful. I just have the feeling this is the future of parks.

 

[ParentsOf4]

For some reason, NextGen makes me think of the opening sequence to the 1967 British TV series, The Prisoner:

Number 6: "Where am I?"
Number 2: "In the Village."
Number 6: "What do you want?"
Number 2: "Information."
Number 6: "Whose side are you on?"
Number 2: "That would be telling. We want information. Information. Information."
Number 6: "You won't get it."
Number 2: "By hook or by crook, we will."
Number 6: "Who are you?"
Number 2: "The new Number 2."
Number 6: "Who is Number 1?"
Number 2: "You are Number 6."
Number 6: "I am not a number! I am a free man!"
Number 2: [sinister laugh]

With NextGen, Disney simply wants "information".

 

[Disneyhead'71]

Spirit, you need to go easy on Mr. Franklin's appearance last Monday. He had a very long Sunday that went late into the night scrambling to put together a PR Defensive after some high spirited fanboi posted, on a popular fan site, a scathing analysis of his pet project.

 

[GoofGoof]

I think that was the point that @WDW1974 was trying to make way back when he first mentioned the recent changes to COPPA. They do have to prove their need to someone, although it doesn't say to whom. All that Disney needs is the right beaurocrats in their pockets and they are off scott free.


That would give them an 'opt out'. I don't think they want an 'opt out'. Then they can maximize profits.

Disney definitely has some powerful political connections. If they need to they will probably pull some strings. It just seems sleazy to me. I think the opt out would be not to use MyMagic+ and therefore not use FP+. They did state that it was optional and guests do not have to use it. You then get stuck waiting in longer lines and your kids will be ed off when they see other people with wrist bands that activate things and get them into the park and their room and they don't have one. As much as some adults are opposed to the wrist bands, kids will eat it up.