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?
Definitely in the ballpark ...