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Connected toys violate European consumer law

The Norwegian Consumer Council has looked at the terms and the technical features of selected connected toys. The findings show a serious lack of understanding of children’s rights to privacy and security.

Based on what was discovered, consumer organizations in Europe and the United States in cooperation file formal complaints to relevant authorities on what seems to be obvious breaches of several consumer laws.

In their review of the toys, the Consumer Council has found several serious issues:

  • Lack of security
    With simple steps, anyone can take control of the toys through a mobile phone. This makes it possible to talk and listen through the toy without having physical access to the toy.This lack of security could easily have been prevented, for example by making physical access to the toy required, or by requiring the user to press a button when pairing their phone with the toy.
  • Illegal user terms
    Before using the toy, users must consent to the terms being changed without notice, that personal data can be used for targeted advertising, and that information may be shared with unnamed 3rd parties.This and other discoveries are, in the NCC’s opinion, in breach of the EU Unfair Contract Terms Directive, the EU Data Protection Directive, and possibly the Toy Safety Directive.
  • Kids’ secrets are sharedAnything the child tells the doll is transferred to the U.S.-based company Nuance Communications, who specialize in speech recognition technologies. The company reserves the right to share this information with other third parties, and to use speech data for a wide variety of purposes.
  • Kids are subject to hidden marketingThe toys are embedded with pre-programmed phrases, where they endorse different commercial products. For example, Cayla will happily talk about how much she loves different Disney movies. Meanwhile, the app-provider has a commercial relationship with Disney.

The day the news came out, Cayla was removed from shops in Belgium and the Netherlands. In Denmark it is still (9 december) available in e.g one of the biggest toy chains Fætter BR.


Read the FTC complaint from EPIC

See more on the Norwegian Consumer’s Council’s website (in English)

Read about the data ethical issues of an internet of toys in this article by’s Gry Hasselbalch:  “A Toy that Wants to Phone Home”

Read “Data ethical considerations for the Internet of Toys” (8 points)