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ARTICLE · 25 MAY 2018

Children's Advertising >> Developments In Connected Technology Create New COPPA Challenges

Davis+Gilbert LLP
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After a resoundingly quiet 2017, the Federal Trade Commission (FTC) started 2018 with a bang, announcing two back-to-back settlements with companies ...

United StatesMedia, Telecoms, IT, Entertainment

After a resoundingly quiet 2017, the Federal Trade Commission (FTC) started 2018 with a bang, announcing two back-to-back settlements with companies alleged to have violated the Children's Online Privacy Protection Act (COPPA).

The FTC's action against VTech Electronics Limited (VTech), the provider of digital learning games and the operator of the "Kid Connect" app for children, marks the FTC's first-ever COPPA case involving connected toys. In 2015, VTech learned that a hacker had breached its network and accessed its customers' personal information, including the personal information of many children. According to the FTC, the children's personal information was linked to their parent's registration data (such as home address), and none of this data was encrypted. The FTC alleged that VTech's collection of personal information from children without appropriate parental notice and consent, and its failure to take reasonable steps to secure the data it collected,

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