COPPA crackdown is no longer an abstract policy concept but a visible force reshaping the way children’s apps and connected toys are designed, as underscored by the recent Federal Trade Commission settlement involving Apitor’s robot companion app. In that matter, regulators alleged that a third-party software component embedded in the app quietly captured and transmitted children’s geolocation data to servers in China without parental consent, despite assurances of compliance in the company’s privacy policy. The enforcement action highlights how location data has become a focal point of regulatory concern and how oversight now extends beyond first-party data collection to the broader ecosystem of software development kits and analytics tools.
This article examines how that enforcement posture is influencing design choices across the kids’ digital ecosystem, what regulators expect from companies that handle young users’ data, and how organizations can adapt their governance, engineering, and product strategies in response.
Regulatory Landscape
The core legal regime at issue is the Children’s Online Privacy Protection Act and its implementing rule, which together govern the online collection, use, and disclosure of personal information from children under 13 by qualifying websites, online services, and connected products. Under this framework, operators of child-directed services or those with actual knowledge that they are dealing with young users must provide clear privacy notices, obtain verifiable parental consent before collecting personal information, and maintain reasonable data security, among other requirements.
The Federal Trade Commission enforces this framework through the COPPA Rule, which clarifies what counts as personal information and operationalizes the statute’s consent, notice, and retention obligations. The rule explicitly lists precise geolocation information as personal information, meaning that collecting such data from children triggers the full set of parental notice and consent requirements. The Apitor case reaffirmed that this applies even when the data is collected by an embedded third-party component, not only by the primary service, reinforcing that companies are responsible for data flows occurring through tools they integrate.
In the Apitor action, the FTC, working with the U.S. Department of Justice, alleged that the company’s companion app required Android users to enable location services to connect the toy, and that once that permission was granted, a third-party SDK transmitted precise geolocation data to servers overseas without any meaningful parental disclosure or consent step. The resulting stipulated order requires Apitor to adhere to COPPA obligations going forward, including obtaining verifiable parental consent, honoring deletion requests, and limiting retention of children’s personal information to what is reasonably necessary for a defined purpose.
Beyond this single matter, recent enforcement activity against other companies, including large media and gaming platforms, signals that children’s privacy is a sustained focus. The FTC has emphasized that configuration choices on platforms and within apps—such as whether content is flagged as child-directed, or whether third-party ad technology is active—can themselves give rise to COPPA exposure. Regulators have also stressed that compliance programs must account for cross-border transfers, especially when data is sent to jurisdictions that raise heightened policymaker concern.
Against this backdrop, coppa crackdown now encompasses not only basic notice-and-consent mechanics but also deeper scrutiny of app architecture, vendor relationships, and the technical means by which data is collected and shared. Companies developing or distributing digital products for children are expected to implement comprehensive privacy-by-design practices that align engineering decisions with regulatory expectations from the outset.
Why This Happened
The recent focus on children’s privacy enforcement reflects several converging dynamics. From a policy standpoint, lawmakers and regulators have increasingly prioritized protecting minors online, viewing children as particularly vulnerable to opaque data collection, profiling, and targeted advertising. This has led to pressure on the FTC to use existing tools, including COPPA, more aggressively to address perceived gaps in industry practices.
Technologically, modern kids’ apps and connected toys often rely on complex stacks of third-party software development kits for functions like push notifications, analytics, and monetization. These components can collect or enable access to personal information, including geolocation, with minimal visibility for parents and sometimes even for the integrating company. The Apitor matter illustrates how this reliance on third-party SDKs can create regulatory risk when integrations are not tightly governed and tested.
There are also geopolitical and policy concerns around data flows to foreign entities, particularly when the data involves children and is sent to servers located abroad. In the Apitor case, regulators highlighted that geolocation data was transmitted to a Chinese developer’s infrastructure, underscoring sensitivity to cross-border transfers involving minors’ information. This intersection of privacy, national security, and digital trade has amplified scrutiny of children’s services that leverage overseas vendors or infrastructure.
Finally, the timing reflects a broader shift from guidance-heavy oversight to more punitive, precedent-setting actions. Regulatory agencies are using high-visibility settlements to clarify expectations, deter non-compliance, and influence industry design patterns. As a result, coppa crackdown is functioning as both an enforcement strategy and a signaling mechanism to change behavior across the market.
Impact on Businesses and Individuals
For businesses operating in the children’s digital ecosystem, the implications of this enforcement trend are substantial. Product teams building kids’ apps and connected toys now face heightened expectations to embed privacy into the earliest stages of design, including decisions about what data is truly necessary to deliver core functionality. An app that requires permissions like geolocation without a clear, proportionate rationale invites scrutiny, especially where younger users are involved and parental awareness is low.
Legal and compliance functions must respond by re-evaluating COPPA programs with particular emphasis on third-party technologies. Organizations integrating SDKs, analytics platforms, or advertising tools into child-directed services are expected to understand precisely what data those partners collect, how it is used, whether it is shared further, and where it is stored or processed. Failure to exercise this level of diligence, as seen in the Apitor context, can lead regulators to treat third-party data flows as if they are directly attributable to the first-party operator.
Financially, the penalties and injunctive relief associated with COPPA violations can be significant. Even where civil penalties are suspended based on inability to pay, companies incur legal costs, monitoring obligations, and remediation expenses, including data deletion, policy revisions, and engineering changes. Larger organizations with greater resources may face substantial monetary penalties, multidimensional compliance programs, and independent assessments, all of which can reshape development roadmaps and operating budgets.
Operationally, companies must be prepared for intrusive oversight from regulators, including long-term reporting, documentation obligations, and potential audits. Orders in recent cases have required robust programs to evaluate content designation, age assurance, and the functioning of integrated tools. These expectations apply not only to U.S. entities but also to overseas manufacturers and developers that reach American children through online marketplaces, demonstrating that coppa crackdown has extraterritorial reach where U.S. users are affected.
For individuals, especially parents and children, the enforcement environment has both protective and practical effects. Parents gain stronger assurances that apps and devices marketed to their children will be more transparent about data use, with clearer disclosures and mechanisms to grant or withhold consent. When regulators require deletion of improperly collected data and impose retention limits, families receive tangible privacy benefits that extend beyond symbolic penalties.
At the same time, businesses may respond by limiting certain features or restricting usage in ways that affect user experience, such as disabling location-based functionality or tightening access to social or interactive components. Some companies may choose to avoid serving under-13 users entirely, or to redesign offerings so they qualify as general audience services with robust age assurance tools, potentially narrowing the range of child-directed experiences but increasing the safety of those that remain.
The enforcement climate also alters organizational decision-making and accountability. Boards, senior executives, and product leaders are more likely to view children’s privacy as a core risk domain that requires formal governance rather than as a niche compliance issue. Misalignment between marketing claims—such as statements of COPPA compliance in privacy policies—and actual technical behavior can expose companies to allegations of deception in addition to COPPA violations, increasing personal and corporate liability.
Enforcement Direction, Industry Signals, and Market Response
The pattern emerging from recent FTC actions suggests a sustained focus on children’s data, with particular attention to geolocation, cross-device tracking, and interactions between child-directed content and advertising technology. Authorities are emphasizing that COPPA obligations apply regardless of who technically collects the data, making it clear that outsourcing functionality to third parties does not dilute responsibility. Public statements from agency leaders have underscored this stance, highlighting that companies must understand and control how partners handle young users’ information.
Across the market, developers, toy manufacturers, platforms, and ad-tech vendors are adjusting their practices. Some are conducting comprehensive reviews of SDK usage in kids’ apps, removing or replacing components that access sensitive data or that cannot provide sufficient assurances regarding children’s privacy. Others are segmenting their product lines, maintaining separate technology stacks for child-directed offerings, or disabling certain analytics and advertising features entirely for younger audiences.
Regulatory signals also point toward broader scrutiny of age designations and age assurance. In actions involving larger media companies, authorities have elevated the importance of correctly flagging content as child-directed and designing workflows to ensure that children are not inadvertently exposed to behavioral advertising systems. In parallel, regulators are convening workshops and publishing guidance on emerging age verification technologies, hinting that future enforcement may evaluate not just whether consent mechanisms exist, but how effectively services distinguish between children and older users.
These developments collectively show that coppa crackdown is reshaping market expectations. Investors, acquirers, and partners increasingly view children’s privacy posture as part of due diligence, influencing valuations and strategic decisions. Vendors that can demonstrate strong COPPA alignment, transparent data practices, and privacy-preserving architectures may gain competitive advantage as risk-conscious clients seek to reduce exposure.
Compliance Expectations and Practical Requirements
Organizations that design or distribute digital products used by children must now treat COPPA compliance as an integrated, multi-disciplinary obligation touching product, engineering, legal, security, and procurement functions. The starting point is an accurate assessment of whether a service is directed to children, has a mixed audience, or has actual knowledge that children under 13 are using it. This classification drives the scope of obligations, including the need for parental notice and consent, data minimization, and tailored user experiences.
Once obligations are triggered, companies must implement clear and accessible privacy notices that accurately describe their information practices, including the role of third parties and the categories of data collected. The Apitor matter illustrates the risk of providing high-level statements of compliance while omitting material details, such as the involvement of an SDK that transmits precise geolocation data abroad. Disclosures should be updated as data practices evolve, and they must be aligned with actual technical behavior verified through testing and monitoring.
Operationalizing consent is crucial. Verifiable parental consent must be obtained before collecting personal information from children, which includes geolocation, persistent identifiers used for tracking, and other enumerated data types. Mechanisms might involve payment card verification, government-issued identification checks, or other methods that reliably establish parental involvement. Critically, the process should be incorporated seamlessly into the user journey, so that access to features requiring sensitive data is gated behind parental approval rather than buried in optional settings.
From a technical standpoint, companies should embrace data minimization and selective permission requests. If an app’s basic functionality does not genuinely require precise geolocation, that permission should not be requested for child users. Even when location is needed, developers can explore less granular alternatives, time-limited collection, or on-device processing that avoids persistent storage. Engineering teams should review how permissions are used within the code base and how integrated components, including SDKs, libraries, and cloud services, interact with those permissions.
Vendor management has become a central pillar of children’s privacy compliance. Before integrating third-party tools into kids’ apps, organizations should conduct due diligence on the vendor’s data practices, contractual commitments, and geographic footprint. Contracts should clearly restrict collection, use, and disclosure of children’s personal information, mandate compliance with COPPA, and provide for audits or detailed reporting. Technical controls, such as disabling certain SDK capabilities or configuring them for limited operation in child-directed contexts, can further reduce risk.
Ongoing monitoring is essential. Companies should periodically scan their applications to identify active SDKs and permissions, review logs to understand actual data flows, and confirm that no new functionality has introduced unexpected collection paths. Privacy and security teams can collaborate on testing to ensure that app updates do not inadvertently expand data collection beyond what is disclosed and authorized. Automated tools can help detect anomalies, such as communication with domains or endpoints that were not anticipated during design.
Common errors to avoid include assuming that only first-party code matters, relying on boilerplate privacy policies that fail to capture real-world practices, and treating coppa crackdown as a one-time project rather than an ongoing compliance lifecycle. Organizations should also avoid designing consent processes that are effectively bypassed by children, such as simplistic self-declaration age gates without further checks when the context suggests significant under-13 usage.
Practical steps companies can take now include mapping all child-related data flows across their products, establishing a dedicated governance committee or working group for kids’ privacy issues, and aligning internal policies with external commitments. Training for developers, product managers, and marketing teams is critical so that they understand COPPA concepts, including what constitutes personal information, how age and audience designations work, and why integrating new tools into kids’ environments requires careful scrutiny.
In parallel, organizations should prepare for broader regulatory developments, such as possible updates to COPPA rules or new federal and state children’s privacy frameworks, by evolving their privacy-by-design practices beyond narrow legal minimums. Approaches that emphasize purpose limitation, granular role-based access controls, and strong encryption for sensitive data will better position companies to adapt to future standards while maintaining operational flexibility.
coppa crackdown in the wake of the Apitor settlement has sent a clear message that children’s apps and connected toys must be built on a foundation of rigorous privacy governance rather than on informal assumptions about risk tolerance. Developers and manufacturers that fail to interrogate the behavior of third-party SDKs, or that treat location and other sensitive data as benign engineering conveniences, are likely to face increasing enforcement exposure as regulators continue to scrutinize the hidden data flows underpinning kids’ digital experiences. At the same time, organizations that embrace transparent design, robust parental engagement, and disciplined vendor oversight can differentiate themselves as trustworthy stewards of children’s information, strengthening both regulatory resilience and market confidence.
FAQ
1. How did the Apitor case illustrate the risks of third-party SDKs in kids’ apps?
Ans: The enforcement action against Apitor highlighted that a third-party SDK embedded in its robot companion app collected precise geolocation data from children without parental consent, showing that companies are accountable for data practices of integrated tools and must vet and control how those tools handle children’s information.
2. Why is children’s geolocation data treated as especially sensitive under COPPA?
Ans: COPPA and its rule classify precise geolocation as personal information because it can reveal where a child lives, studies, or spends time, creating safety and profiling risks. Collecting this data from users under 13 requires clear parental notice and verifiable consent, and regulators closely scrutinize its use, storage, and sharing.
3. What design changes should kids’ app developers consider after recent COPPA enforcement?
Ans: Developers should minimize data collection, request only necessary permissions, gate sensitive features behind verifiable parental consent, and avoid relying on default SDK configurations. They should also implement privacy-by-design practices, verify that configuration changes do not enable unintended tracking, and maintain accurate, up-to-date disclosures.
4. How can companies manage COPPA risks when using third-party vendors and analytics tools?
Ans: Companies should conduct due diligence on vendors, ensure contracts explicitly require COPPA compliance, restrict data use and sharing, and configure tools for child-safe operation. Ongoing monitoring, including technical testing and log reviews, is important to confirm that vendors are not collecting or transmitting children’s data in unapproved ways.
5. What practical steps can toy manufacturers take to align connected products with COPPA?
Ans: Toy manufacturers should map all data flows associated with their apps and devices, determine whether offerings are child-directed, implement parental consent mechanisms, and limit collection to what is reasonably necessary. They should also provide transparent notices, enable data deletion upon request, review third-party integrations, and maintain governance structures dedicated to children’s privacy compliance.