CARU’s 2021 Tips for Parents: Safe and Efficient Holiday Shopping

Dec 14, 2021 by Rashida Gordon, Analyst, Children’s Advertising Review Unit, BBB National Programs

Though much of this year may have felt uncertain, one thing that is certain is the state of 2021 holiday shopping: it is once again primarily online. 

To help ensure your online holiday shopping experience is safe and efficient, the team at BBB National Programs’ Children’s Advertising Review Unit (CARU), responsible for protecting children and their data from irresponsible practices in the online environment since 1974, has put together some tips and red flags to consider when making your all-important gift selections. 


Making a List and Checking it Twice 

If the COVID-19 pandemic has continued to keep you away from relatives, you may feel at a loss when trying to pick the best presents for those socially distant nieces, nephews, and grandchildren. Each year popular online retailers compile their picks for the year’s hottest toys to give you some food for thought. 

Here are a few points to think about when looking at “Hot Toys of 2021” lists. 


Safety and Privacy

Retailers select toys for these lists based on whether they think the toy will be a bestseller. What they may not consider is whether the toy is “safe” or, if it is a smart toy, whether it has responsible data collection practices. If you are looking at toys that connect to the Internet or mobile devices, you want to be comfortable with a toy’s data collection and privacy practices. It’s important to read the company’s privacy policy. 

A good privacy policy should: 

  • Be written in plain English and be understandable to ordinary consumers,
  • Describe WHAT personal information the toy collects from its users,
  • Define WHO is collecting or has access to the information,
  • Include HOW that information is being stored,
  • Explain HOW and WHY the information is being used, and
  • Outline what parental rights you must review or remove that information.


The Children’s Online Privacy Protection Act (COPPA) is a federal law that requires websites and online services directed to children under age 13—including connected toys and apps – to give parents notice of their information practices and get a parent or guardian’s consent before collecting personal information from children.    

An easy way to know if apps and connected toys comply with COPPA or other privacy laws is to find a company that participates in an FTC-approved Safe Harbor, such as CARU’s COPPA Safe Harbor program. If you see a CARU COPPA Safe Harbor seal on a website, app, or connected toy you can rest assured that its privacy practices comply with CARU’s Guidelines and COPPA and that no personal information will be collected from your child without your explicit consent. 


Truthfulness and Transparency 

Another factor to consider when looking at “Hot Toys of 2021” lists is that some toys are featured because of sponsorship as opposed to the quality and nature of the toy itself. Often, toy lists are structured so that the owner/creator of the list receives money after consumers click on the links provided to purchase the product.


Naughty or Nice? Buyer Beware 

Online shopping takes away the ability to see and touch products, leaving shoppers to depend on the accuracy and availability of product information on a retailer’s website. Be sure to read product details carefully so you know exactly how the product works as well as what comes with it. Be mindful of what (if any) accessories must be purchased separately. These could be items like batteries or additional products such as clothing for dolls or items to complete a set. 

Because online depictions of a product may not always be clear, many online shoppers find it helpful to read online reviews or watch videos of the product to get a closer look. It is important to be aware that reviewers, influencers, and bloggers may be getting compensated for their opinions, for example by being paid money or receiving free product from the companies in exchange for posting a review.

Part of CARU’s mission is to protect children from deceptive or inappropriate advertising, including endorsements and reviews, including those ever-popular unboxing videos, that don’t disclose the paid relationship between the product and the reviewer or influencer. Viewing online reviews with your children can be a good teaching opportunity to educate them about carefully evaluating influencer posts and reviews. 


Good Things Come in Small (Age-Appropriate) Packages 

Even the best toy is only great if it’s purchased for a child of an appropriate age. Age recommendations, frequently found on the front of a toy package, may be less readily apparent while shopping in an online environment so it’s important that gift buyers look closely for them. The U.S. Consumer Product Safety Commission provides companies with Age Determination Guidelines that may be helpful to review. 

Toys meant for teenagers may be inappropriate for younger children or may require adult supervision. Furthermore, connected toys intended for an older child may collect personal information, like audio and video recordings, without notifying parents or getting their consent (a requirement of COPPA for toys intended for children under age 13). 

In addition, companion apps for connected toys may also have information collection practices inappropriate for children, such as location tracking or behavioral advertising (ads targeted based on web browsing history), or they may link to sites that are unsuitable for children, like social media platforms. To learn more about the risks of behavioral advertising and in-app purchases, you can read our blog post on the topic. 


You Better Watch Out…

When you’re waiting for your special deliveries, be aware that phishing attacks – emails from faked senders designed to get your personal information – are on the rise during the pandemic. Be mindful when opening emails that appear to be from stores, but don’t look quite right. If you made a purchase online, make sure emails are coming from the company’s authorized email address. If you are nervous or suspicious of an email, don’t click on anything in the email, especially attachments.

Similarly, if you receive a text message from a company confirming your purchase and/or advertising a promotion, exercise caution when clicking on the links provided. Instead, refer to the original order confirmation email or navigate to the company’s website to check the status of your order. Pandemic or not, during the holiday season it also never hurts to keep an eye on your credit card statements to catch any suspicious activity. 


Let Us Know, Let Us Know, Let Us Know

Remember, Santa isn’t the only one with a “Naughty or Nice” list. If you see products, toys, connected devices, or advertisements this holiday season that get your online tinsel in a virtual twist, use our CARU Consumer Complaint form to get in touch. We review each complaint we receive.

Suggested Articles


Fifty Shades of Consumer Health Data: Unclear Expectations for Digital Privacy

While momentum continues to build around what a regulated consumer health privacy landscape looks like, the environment remains shrouded in shades of gray. To date, a risk-based approach to consumer health data does not exist, but we believe a sliding scale for the risks carried by consumer health data should.
Read more

Fifty Shades of Consumer Health Data: How a Risk-Based Approach Provides More Clarity

This piece includes a list of routine examples of consumer health information, that, at face value may have one level of risk. But, depending on the context and the risk associated with the use of that data, and whether it is combined with other data sources and data elements or made available in the public domain, it could lend itself to differing levels of regulation and enforcement activity.
Read more

California Privacy Enforcement: Whose Job Is It Anyway?

The California Privacy Rights Act of 2020 went into effect bringing new privacy rights to California consumers and created the California Privacy Protection Agency. CCPA will continue to be enforced by the California Office of the Attorney Genera. Which begs the question: Whose enforcement is it anyway?
Read more

Unsubstantiated Claims May Lead to Civil Penalties

The U.S. economy is built on a fair and transparent product marketplace. It is the responsibility of companies to have adequate substantiation for health and safety claims and to hold their competitors to the same standard.
Read more