For a child under 13, the Children’s Online Privacy Protection Rule (COPPA) says a company that runs an online service must get verifiable parental consent before it collects, uses or discloses the child’s personal information. The rule’s definition of personal information includes location data and recordings of a child’s voice, which are exactly what a kids’ smartwatch handles. The catch is that the FTC texts read for this article do not name smartwatches. They name mobile apps, connected toys and other internet-enabled devices, so how the rule applies to a particular watch is a question of how that product works.
Who counts as a child, and what counts as personal information
The rule’s definitions sit in 16 CFR 312.2. A child is “an individual under the age of 13.” That cutoff matters for a family choosing a watch for a ten-year-old and then keeping it going at fourteen, because the protection described here stops applying once the child passes 13.
Personal information under the same section is a longer list than most parents expect. It includes a photo, video or audio file that contains a child’s image or voice. It includes “geolocation information sufficient to identify street name and city or town.” It also covers a persistent identifier, which is a code that lets a service recognize a device over time, and a biometric identifier. A watch with a call feature, a camera and a location map touches nearly every item on that list in a normal week.
What operators must do first
The consent requirement is in 16 CFR 312.5: “An operator is required to obtain verifiable parental consent before any collection, use, or disclosure of personal information from children.” The word “before” carries weight. Consent is meant to come first, not to be a checkbox found after the service has started gathering data.
The FTC’s consumer page, Protecting your child’s privacy online, puts it in plain terms: the COPPA Rule “requires those sites and services to notify parents directly and get their approval before they collect, use, or disclose a child’s personal information.” It adds that the privacy policy “must give details about the kind of information the site collects, and what it might do with the information.” So a parent has two things to read, the direct notice and the policy.
Does COPPA reach a smartwatch?
The FTC’s COPPA frequently asked questions say that “mobile apps and IoT devices, such as smart toys” are online services subject to the rule. It lists internet-enabled gaming platforms, connected toys, smart speakers and voice assistants among the covered services. It also states that “COPPA covers the collection of geolocation information, not just its use or disclosure.” That last point answers a common worry. A company cannot say it only stores a child’s location and never uses it, because collection alone is covered.
What the page does not do is mention wearables by name. A watch that pairs with a parent’s app is an internet-connected device with an app attached, which sits comfortably in the categories the FTC lists. Even so, the exact reach for a given product depends on facts the FAQ does not address, such as who the operator is and whether the service is directed to children. If the answer matters to you, an attorney or the FTC can say more than this article can.
What to check on the day you set one up
| Question to ask | Why it matters | What the FTC text says |
|---|---|---|
| Did the company contact me directly before collecting anything? | Consent should come before collection | Operators must notify parents directly and get approval first |
| Does the privacy policy say what is collected? | Location, voice and photos are all personal information | The policy must detail the kind of information collected and what may be done with it |
| Is location collected continuously? | Collection alone is covered, not just sharing | COPPA covers collection of geolocation information |
| Can I see, limit or delete what was gathered? | Parents keep some control after consent | Parents can review the information, withdraw permission and request deletion |
What parents can ask for after the watch is on a wrist
The FTC consumer page says parents have rights beyond the first consent. You can review the information a company has collected about your child, withdraw your permission, and ask for the information to be deleted. If a company will not answer, or you think it collected data from your child without the notice and approval described above, the FTC points to ReportFraud.ftc.gov for reporting a violation.
In practice, it helps to do the asking in writing and keep a copy. Name the device, the account and the child’s age range, and state which of the three things you want. Keep the reply. That is general advice from the way these rights are phrased, not a procedure laid out by the agency.
What the rule does not settle
COPPA governs the company, not your household. It does not tell you whether tracking your child is a good idea, how much to tell the child, or when to stop. Those choices are yours and they change as the child grows. Our comparison of GPS watches for kids covers how the devices differ in practice, and the family monitoring guide looks at the wider question of how much watching a family needs.
One safety point belongs here. A watch is not an emergency service. If a child is missing or in danger, call 911 first, then use the app. And if you suspect that a stranger has gained access to the watch account, change the account password and contact the manufacturer and your local police.
Our take
COPPA gives parents of children under 13 real pull with a company: consent first, a readable policy, and rights to review, withdraw and delete. The FTC texts do not name smartwatches, so read the policy for the specific watch and keep your requests in writing. After 13, the rule stops applying.
Common questions about kids’ smartwatches and COPPA
Does COPPA apply to my 14-year-old?
No. The rule defines a child as an individual under the age of 13, so its parental consent requirement does not cover a 14-year-old.
Is a child’s location data protected under COPPA?
Yes. The rule counts geolocation information sufficient to identify street name and city or town as personal information, and the FTC says COPPA covers collection of that information, not just its use or disclosure.
Can I ask a company to delete my child’s data?
The FTC consumer page says parents can review what has been collected, withdraw permission and request deletion. Make the request in writing and keep a copy.
Where do I report a company that ignored the rules?
The FTC directs people to ReportFraud.ftc.gov to report violations of the COPPA Rule.
Behind this review
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