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Sticking a Hand in the Internet Cookie Jar

By Jeffrey Higel, Michael Bahar and Mike Nelson
February 01, 2019

As convenient, useful and cool mobile technology and interconnected devices are, they come with risks that remain largely unseen or, worse, ignored. Some pose security risks, like those present in voice-activated devices that can access bank information, unlock doors, and control water temperature, and others pose privacy risks — especially for children. For manufacturers, they also pose regulatory litigation, and insurance risks, especially when children end up using their “smart” products. For example, California's recently passed Internet of Things cybersecurity law will be requiring “reasonable security features.”

In addition to data breaches involving this sensitive data — compromises that could follow a child through his or her entire life — one of the key laws that makers of IoT devices have to worry about is COPPA, the Children Online Privacy Protection Act.

Collecting Data Under COPPA

Under COPPA, any company that collects information, directly or indirectly, must provide parents with detailed terms and conditions, allow parents to stop the company from gathering data at any time, take reasonable steps to safeguard the data, and delete the data once the purpose of the collection has been fulfilled.

Furthermore, the company is not allowed to distribute any child's information to any third party, with a few, limited exceptions.

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