The settlement between VTech Electronics Ltd. and the FTC in the first Internet-connected toys COPPA case is a reminder for companies looking to enter the connected toys space not to forget this child-focused law.

The FTC complaint alleged that VTech violated the Children’s Online Privacy Protection Act and the FTC’s COPPA Rule because it collected personal information from children without parental consent. According to the FTC, VTech markets and sells various “electronic learning products,” which it targets to 3- to 9-year-olds. Those products have an area similar to an app store, and one of the apps available is called Kid Connect. Kid Connect, the FTC explained, lets children communicate with other users. Although parents did have to sign children up for the interactive features of the VTech products, the FTC had concerns about the compliance of the consent process. Namely, that VTech did not have a way to verify that the person submitting consent was the parent, not the child him or herself. Also of concern for the FTC, and in violation it alleged of COPPA, was not having a link to the privacy policy in all areas of Kid Connect where personal information was collected. And in some instances, like the Kid Connect registration page, the privacy policy link was not sufficiently prominent. Additionally, some of the information required by COPPA to be included in a privacy policy was missing. This included VTech’s address and email address, a full description of what information was being collected from children, and the parent’s right to review/delete children’s personal information.
Continue Reading Connected Toys, COPPA, and What’s Next