If your app or connected toy is directed to children under thirteen, or you knowingly collect data from them, the federal children's privacy rule applies — and it requires clear notice to parents, verifiable parental consent before you collect anything, collection limited to what the feature actually needs, retention limits with real deletion, reasonable security, and a way for parents to review and delete their child's data. Those obligations shape the app architecture, so they have to be settled before you write code, not during store submission.
Important: Projects House is an engineering firm, not a law firm or regulatory consultancy. This is an engineering overview of how children's privacy requirements affect product design. Work with qualified privacy counsel on your specific product, audience, and markets.
Children Are a Protected Audience, and Enforcement Is Real
Children's privacy is one of the most actively enforced areas of US consumer protection, with substantial penalties assessed against app developers, toy makers, and platform operators. On top of the federal rule, the app stores impose their own kids-category requirements — restrictions on third-party advertising and analytics, separate review criteria, and mandatory disclosures. Several states have added their own children's design and privacy statutes, and products sold into schools bring education-records rules and district procurement review with them.
The commercial risk is not just fines. A rejected store submission or a pulled listing can strand a physical product that has already been manufactured and shipped to retailers.
Who It Applies To
The test is not what you intended but how the product presents and who uses it. Regulators look at subject matter, visual and audio content, characters, activities, advertising placement, and evidence about the actual audience. A cheerful cartoon interface and a toy form factor point to a child-directed product regardless of what your terms of service say.
Two other paths pull you in. A mixed-audience service — appealing to children but not primarily aimed at them — can use a neutral age screen and apply the stricter rules only to users who identify as under thirteen. And actual knowledge matters: if a general-audience product learns that a particular user is a child, the obligations attach from that moment. Third-party SDKs do not shield you either; if an embedded advertising or analytics library collects identifiers from your child users, that is your problem to answer for.
What Counts as Personal Information Here
Broader than most teams expect: name, address, email, phone number, screen names that function as contact details, precise geolocation, photos, video, audio recordings of a child's voice, biometric identifiers, and persistent identifiers such as advertising IDs, device IDs, and cookies used to recognize a user over time. That last category is what most often catches connected toys, because it is collected by default by ordinary analytics and crash tooling.
What This Means in the Design of the App
- Parent-account architecture. The account belongs to the adult. The child gets a profile inside it. This one decision resolves most of the consent and access questions cleanly.
- A neutral age gate, presented once, that does not nudge toward an older age and that the user cannot trivially retry.
- Verifiable parental consent before any collection, using an accepted method rather than an unchecked "I am a parent" checkbox. Build the consent record — method, timestamp, scope — as first-class data you can produce on request.
- Collect nothing you do not need. If the toy works without an account, do not require one. If it needs a nickname, do not ask for a real name. Never condition play on unnecessary data.
- No behavioral advertising SDKs, and no analytics that build cross-app profiles. Choose tooling that supports a children's mode with identifiers disabled, and confirm what each SDK actually transmits.
- Disable free-form social features by default. Open chat, photo sharing, and user-generated content are the highest-risk surfaces in any kids' product.
- Process locally where you can. Voice recognition performed on the device, with nothing uploaded, removes a whole category of obligation.
- A parent dashboard that shows what is stored, exports it, and deletes it — including revoking consent and having the child's data actually removed.
These are ordinary security-by-design measures applied to a stricter audience; the general baseline is in IoT security for connected products.
Data Lifecycle: Retention, Deletion, and Incidents
Write a retention schedule before launch, per data type, with a stated purpose and a deletion trigger. Then make deletion real: it has to propagate to backups, logs, analytics warehouses, and any processor you send data to. "We stopped showing it" is not deletion.
Have an incident plan too. State breach notification laws apply, timelines are short, and a plan drafted during an incident is a plan drafted badly. Know in advance what you store, where it lives, and who you would need to notify — much easier if you kept the data footprint small in the first place. The cost side of running that infrastructure is in IoT cloud costs.
The Physical Product Is Regulated Too
A connected toy carries two compliance stacks. Alongside privacy, the hardware must meet children's product safety requirements — mechanical hazards, small parts, materials testing, secured battery compartments, tracking labels, and third-party lab testing — as set out in children's product development and CPSIA. Any radio needs FCC certification, and a rechargeable lithium cell brings its own transport-testing obligations. Design decisions cut across both stacks: a physical microphone mute with a visible indicator is simultaneously a privacy feature, a parental trust feature, and a marketing feature.
How to Approach It Properly
Put privacy requirements into the specification at the same time as the feature list — the discipline described in writing a product requirements document. Produce a data map naming every field, every SDK, every destination, and every retention period. Have counsel review the notice, the consent flow, and the vendor agreements before store submission, not after a rejection. Then confirm what the store's kids-category review will ask for, using publishing an app to the app stores as a starting point. The ongoing budget side is in app maintenance costs after launch, and the wider service on our app development pillar page.
If you are building a connected product for children, Projects House can design the hardware, firmware, and app around a minimal data footprint from the start — which is far cheaper than retrofitting it after a store rejection. Tell us about your product through the contact form.