VTech sells (among other things) “electronic learning products” targeted to children ages 3-9. Primarily at issue in the FTC’s complaint was an app called Kid Connect that could be used by children through some of these toys. To use Kid Connect, a parent first had to register an account through VTech’s Learning Lodge website and then set-up Kid Connect accounts for themselves and their child(ren). By November 2015, there were over 638,000 Kid Connect child accounts.
Once registered, children could use Kid Connect to communicate with contacts who had been authorized by the child’s parent by using a direct-messaging feature or posting to a message board. Per the FTC, VTech collected COPPA-regulated personal information from Kid Connect users, “including the content of text messages or messages to shared electronic bulletin boards, user names for a child that could be used to contact the child, and photographs and audio files containing a child’s image or voice.” Continue Reading