Entertainment & U.S. Federal Privacy Law: What Media and Gaming Companies Must Know
Filed in Federal Privacy — December 18, 2025
Introduction
The entertainment industry—including streaming platforms, gaming companies, digital media producers, and content distributors—relies heavily on user data to personalize experiences, deliver targeted content, and monetize engagement. Viewer behavior, account information, device identifiers, and in some cases location data are routinely collected as part of normal operations.
Because entertainment platforms often reach children and teens, they face heightened regulatory scrutiny under U.S. federal privacy law. Two legal frameworks are particularly relevant:
- The Federal Trade Commission Act (FTC Act), which prohibits unfair or deceptive acts or practices; and
- The Children’s Online Privacy Protection Act (COPPA), which governs the collection and use of personal information from children under the age of 13.
Recent enforcement actions show that the Federal Trade Commission (FTC) expects entertainment companies to take active responsibility for how their content, platforms, and monetization practices impact consumer and children’s privacy—even when operating on third-party platforms.
Key Federal Privacy Obligations for Entertainment Companies
Federal Trade Commission Act (FTC Act)
Under the FTC Act, entertainment companies must ensure that their privacy practices are truthful, transparent, and consistent with what is disclosed to users. This includes:
- Accurately describing how user data is collected, used, shared, or monetized
- Avoiding misleading representations about data protection or privacy safeguards
- Implementing reasonable data security measures to protect consumer information
If a company’s public statements or platform design contradict actual data practices, the FTC may consider that conduct deceptive or unfair under federal law.
Children’s Online Privacy Protection Act (COPPA)
COPPA applies to online services and content directed to children under 13, as well as services that have actual knowledge they are collecting personal information from children. Key requirements include:
- Providing clear notice to parents about data collection practices
- Obtaining verifiable parental consent before collecting or using a child’s personal information
- Allowing parents to review or delete their child’s data
- Maintaining reasonable security protections for children’s data
Importantly, COPPA obligations can apply even when content is distributed through third-party platforms, such as video-hosting or app-distribution services.
Verified FTC Enforcement Actions in the Entertainment Sector
Walt Disney Company — COPPA Settlement ($10 Million, 2025)
In September 2025, the FTC announced that The Walt Disney Company agreed to pay $10 million to settle allegations that it violated COPPA. The FTC alleged that Disney failed to properly designate certain child-directed YouTube videos as “Made for Kids,” which allowed the collection of personal data from children without verifiable parental consent.
According to the FTC, this misclassification enabled targeted advertising and data collection practices that COPPA prohibits when content is directed to children under 13. As part of the settlement, Disney agreed to implement a compliance program to ensure accurate audience designation and COPPA compliance going forward.
Why this matters:
This case makes clear that entertainment companies remain responsible for COPPA compliance even when distributing content through third-party platforms. Proper audience classification and ongoing monitoring are essential.
Cognosphere (HoYoverse / Genshin Impact) — FTC Settlement ($20 Million, 2025)
In January 2025, the FTC announced a $20 million settlement with Cognosphere, the developer of the popular game Genshin Impact. The FTC alleged violations of COPPA and federal consumer protection law, including the collection of personal information from children under 13 without parental consent and misleading practices related to in-game purchases.
The settlement requires Cognosphere to:
- Prohibit certain monetization features for users under 16 without parental consent
- Improve transparency around virtual currency and loot-box mechanics
- Delete data collected from children unless parental consent is obtained
- Implement a comprehensive privacy and compliance program
Why this matters:
The case highlights the FTC’s focus on how entertainment platforms monetize engagement, particularly where minors are involved. Privacy compliance now extends beyond data collection into user experience design and billing transparency.
Key Compliance Takeaways for Entertainment Decision-Makers
Entertainment companies should consider the following steps to reduce federal privacy risk:
- Accurate Audience Classification
Regularly assess whether content is directed to children and ensure proper labeling across all distribution channels. - Parental Consent Mechanisms
Implement verifiable parental consent processes wherever children’s data may be collected. - Transparent Privacy Disclosures
Ensure privacy notices clearly explain data collection, usage, sharing, and monetization practices in plain language. - Review Monetization Features
Evaluate in-game purchases, virtual currencies, rewards, and advertising mechanisms for potential consumer protection or children’s privacy risks. - Third-Party Platform Oversight
When using platforms such as video hosting services or app marketplaces, confirm that platform settings align with your legal obligations. - Data Security and Retention Controls
Protect user data with reasonable security measures and limit retention to what is necessary for legitimate business purposes.
How The Data Privacy Lawyer PLLC Supports Entertainment Companies
At The Data Privacy Lawyer PLLC, we help entertainment and media companies navigate U.S. federal privacy requirements by:
- Reviewing content distribution and audience classification practices
- Advising on COPPA compliance and parental consent frameworks
- Assessing privacy risks in monetization and engagement features
- Drafting and updating privacy policies and internal compliance programs
- Supporting companies during regulatory inquiries or enforcement risk assessments
Contact us
The Data Privacy Lawyer PLLC
🌐 www.thedataprivacylawyer.com
📧 info@thedataprivacylawyer.com
📞 +1 (202) 946-5970
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