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Smart Toys for Kids May Be Too Smart

CARU Warns Parents: Beware of Privacy Concerns with Smart Toys for Kids

With the advent of the Internet of Things, toys for kids and toddlers are increasingly becoming “smart” in that they can now upload and download information or data wirelessly from the Internet. 

CARU and COPPA Seek to Protect Children

According to the Children’s Advertising Reviewing Unit (“CARU”), more and more toys are now able to wirelessly connect to the Internet, and as such, may be collecting the personal information of children.  The information collected by these toys may include, but are not limited to, names, addresses, email addresses, gender, and age.  

While many manufacturers have taken the steps to try to require parental permission before uploading or sharing such data, CARU notes that there is a worrying amount of toys that do not have proper safeguards in place to prevent children from faking parental acceptance, or the toys simply do not request permission at all.

CARU’s Tips for Smart Toy Purchasing

As the holiday season unfolds, CARU has a few tips for parents looking to purchase IoT integrated smart toys for children without having to worry about compromising their personal data.  First, CARU suggest that parents research the toy on the Internet and check pertinent reviews.  Because manufacturers are not required to list any specific disclosures about collecting personal information from children on their boxes or packaging, it is important for parents to do their own research.

Second, CARU recommends that parents actually read the privacy policy that may accompany a toy or be available on the manufacturer’s website.  If the company simply does not have one available, this should be a huge red flag to consumers.  Third, parents should know their rights under the Children’s Online Privacy Protection Act (“COPPA”).  If a smart toy does end up collecting a child’s personal information, parents should be aware that COPPA requires notice to be given prior to the collection of personal data. 

A few other quick suggestions from CARU include: 1) using a virtual private network (“VPN”) for privacy; 2) unchecking some of the default checkboxes that permit manufactures to collect personal information; 3) staying apprised of any changes to applicable privacy law or changes to the manufacturer’s privacy policy; 4) monitoring your child’s use of the toy; and 5) turning off the “smart” toy when not in use.

Key Takeaways From CARU Regarding Smart Toys for Kids That Connect To The Web 

As parents select toys with IoT technology for their kids, they should remember that there are privacy and security concerns to keep in mind:

  • New technology can create the unauthorized sharing of a child’s personal information;

  • IoT can result in unauthorized recording or streaming of a child’s activities;

  • Some toys may allow unsecure connections to be accessed within the house; and

  • Read the privacy policies and ensure you opt out where you feel uncomfortable, and stay away from IoT products that don’t come with clear privacy policies.


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About the Firm:

Klemchuk LLP is a litigation, intellectual property, transactional, and international business law firm dedicated to protecting innovation. The firm provides tailored legal solutions to industries including software, technology, retail, real estate, consumer goods, ecommerce, telecommunications, restaurant, energy, media, and professional services. The firm focuses on serving mid-market companies seeking long-term, value-added relationships with a law firm. Learn more about experiencing law practiced differently and our local counsel practice.

The firm publishes Intellectual Property Trends (latest developments in IP law), Conversations with Innovators (interviews with thought leaders), Leaders in Law (insights from law leaders), Culture Counts (thoughts on law firm culture and business), and Legal Insights (in-depth analysis of IP, litigation, and transactional law).