Children’s Advertising Review Unit Finds TickTalk Tech in Violation of COPPA and CARU’s Privacy Guidelines; Company Agrees to Corrective Actions
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McLean, VA – March 08, 2022 – The Children’s Advertising Review Unit (CARU) of BBB National Programs has found TickTalk Tech, LLC, owner and operator of the TickTalk 4 Smart Watch phone and coordinating app, in violation of the Children’s Online Privacy Protection Act (COPPA) and CARU’s Self-Regulatory Guidelines for Children’s Online Privacy Protection. TickTalk agreed to correct the violations.
The TickTalk 4 Smart Watch phone, its website, and the TickTalk 4 app came to CARU’s attention through its routine monitoring of privacy practices affecting children. CARU, the nation’s first FTC-approved COPPA Safe Harbor Program, monitors online services, including but not limited to websites and mobile apps, for compliance with COPPA and CARU’s Privacy Guidelines to ensure that children’s data is collected and handled responsibly.
Further, according to CARU, TickTalk did not provide a means for parents to provide verifiable consent to its information collection practices prior to the collection of information from children. Even if TickTalk had included a verifiable parental consent mechanism during registration or set-up, parents could not provide meaningful consent, given TickTalk’s failure to provide clear, complete, and non-confusing notice of its practices regarding the collection and use of children’s personal information.
Therefore, CARU determined that TickTalk violated COPPA and CARU’s Privacy Guidelines.
CARU recommended that TickTalk take the following corrective actions:
- In immediate proximity to notice of its collection, use and disclosure practices, and prior to parents’ completion of the registration process, provide a clear, prominent, and unavoidable means to obtain verifiable consent from parents to such practices.
- Take necessary steps on the operator’s website and other advertising and marketing materials to clearly and prominently present all material information about the functionality and uses of the online service, prior to the registration and set-up process.
TickTalk participated in CARU’s self-regulatory program and provided CARU with a detailed plan to remedy the concerns raised in the decision to comply with COPPA and CARU’s Privacy Guidelines.
About BBB National Programs: BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org.
About Children’s Advertising Review Unit: The Children’s Advertising Review Unit (CARU), a division of BBB National Programs and the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children from deceptive or inappropriate advertising and ensure that, in an online environment, children's data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action.
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