Sharing Holiday Cheer (but Not a Child’s Personal Information)

Not surprisingly, cell phones, connected toys, and toys advertised on social media top wish lists of kids everywhere. To keep you informed and help ensure your holiday shopping experiences are as safe as possible, the team at BBB National Programs’ Children’s Advertising Review Unit (CARU) put together some holiday tips.

CARU helps companies comply with laws and guidelines that protect children under age 13 from deceptive or inappropriate advertising and ensure that, in an online environment, children’s data is collected and handled responsibly. CARU has been doing this work for the last 50 years, navigating the shift from radio and TV to digital and apps. 

Online Toy Purchases

When we shop online, we are not able to see or touch products before we purchase, leaving us to depend on the accuracy and availability of product information on a retailer’s website. When shopping online, keep the following in mind: 

• In determining which toys to purchase, consumers often reference “Hot Toy” lists. Sometimes toys are featured and highly ranked because of sponsorship as opposed to the quality and nature of the toy itself. These toy lists are often structured so that the owner/creator of the list receives money when consumers click on the links provided to purchase the product. Sometimes you will see “Sponsored by” on a specific product description or list, so look closely. 
• Because online depictions of a product may not always be clear, many shoppers find it helpful to read online reviews or watch videos of the product. When taking this route, it is important to look for verified reviews. Verified reviews are independent, whereas some reviewers, influencers, and bloggers get compensated for their opinions, which can include being paid money or receiving free product from the companies in exchange for posting a positive review.
• 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. 

Part of CARU’s mission is to protect children from deceptive or inappropriate advertising, including endorsements and reviews such as those ever-popular unboxing videos that do not always disclose the paid relationship between the product and the reviewer or influencer. Viewing online reviews with your children can be an opportunity to educate them about the persuasive intent of posts and reviews and encourage good digital citizenship.

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. You may receive a phishing email about a missed delivery or pending order. Be mindful when opening emails or texts that appear to be from stores or delivery services, but don’t look quite right. These emails may even reference major retailers in the subject line. 

If you made a purchase online, make sure emails are coming from the company’s authorized email address. Hover over the email address to determine the actual sender. If you are suspicious of an email, don’t click on anything in the email, especially attachments.

Similarly, if you receive a text message from a company advertising a promotion or notifying you of a missed delivery, exercise caution when clicking on any link provided. Instead, refer to the original order confirmation email, or navigate to the company’s website to check the status of your order. 

“AI”, “Smart,” and “Connected” Toys

Toys and games (VR or otherwise) may have microphones, sensors, or cameras that collect data. This data may include personal conversations and household interactions, location, biometric, and other personal information. Unfortunately, “smart” is not always synonymous with “safe.” 

Ensure any toy you choose has responsible data collection practices. In addition to the actual toy, companion apps may also have information collection practices inappropriate for children, such as behavioral or personalized advertising (ads targeted based on the consumer’s web browsing history), or they may link to sites that are unsuitable for children, such as social media platforms.

It is important to read the company’s privacy policy. A good privacy policy should: 

• Be written simply and easy to understand,
• Describe WHAT personal information the toy collects from its users,
• Define WHO is collecting or has access to the information (that is, who data may be shared with),
• Include HOW that information is being stored and protected,
• Explain HOW and WHY the information is being used, and
• Outline what parental rights you have to 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 COPPA and that no personal information will be collected from your child without your explicit prior consent. 

Toys and metaverse games meant for teenagers (check age recommendations) 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 prior consent (a requirement of COPPA for toys intended for children under age 13). 

Gifting Smart Phones

If you are gifting a cell phone to a child, set up the phone before you gift it. Open it, charge it, and most importantly, set up parental controls. Parental controls allow you to make decisions regarding content, screen time, purchases, browsing, and many other settings including notifications and information shared.  It may seem obvious but do not share the passwords to access parental controls or other parental apps with your child.

CARU recommends preloading the phone with a few safe apps. How do you identify a "safe" app?

• Most social media apps are intended for users 13 and over. Some platforms have teen and kid settings that default to the most protective settings; however, it remains important to read the privacy policies and adjust the settings if need be.
• Research apps before downloading – read reviews and check out services that rate children’s apps. If there is not much information online about an app, be careful because some apps can contain malware. 

In addition, share with your child some general phone safety that we all know and practice, but a child just starting cell phone usage will not:

• Always lock your phone when you aren’t using it and be aware of your surroundings when you have your mobile device.
• Do not join a Wi-Fi hotspot that you don’t recognize. Don’t assume that hot spots with the name “Free Wi-Fi” or “Public Wi-Fi” are legitimate or safe.
• Disable automatic Wi-Fi connections and file sharing.
• Keep your mobile phone updated.
• Establish with your child that the phone is a tool, not a toy.
• Set an expectation of privacy – let your child know that you will periodically check their phone to ensure they remain safe.
• Have an ongoing conversation with your child about their use of their phone – emphasize quality over quantity.
• Explain your expectations on the types of appropriate content.
• Emphasize good digital citizenship and the concept of a digital footprint.

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.

Happy Holidays!