Product safetyConnected toys violate overall and specifically children’s consumer rights

Today, the Norwegian Consumer Council (NCC) presented its review report on the terms and technical features of the internet-connected toys “My Friend Cayla” and “i-Que”. As part of a larger NCC project focusing on the Internet of Things (IoT), the report reveals that these connected toys are subject to a severe lack of understanding regarding overall and specifically children’s rights to privacy and security. These are the report’s central findings:


  • Lack of security: The toys can be easily remote-controlled through mobile devices. That is, anyone could potentially talk and listen through the toy without having physical access to it.
  • Illegal user terms: Before using the toy, consumers must agree that the terms of use may be changed without notice. Moreover, users have to consent that personal data can be used for targeted advertising and that information may be shared with unnamed third parties. In the NCC’s view this constitutes a clear breach of the EU Unfair Contract Terms Directive, the EU Data Protection Directive and possibly the Toy Safety Directive.
  • Kids’ secrets are shared: Any communication data between the child and the toy is being collected and transferred to the US-based company Nuance Communications that specializes in speech recognition technologies. Furthermore, the company reserves the right to share this information with third parties, and to use speech data for a variety of purposes.
  • Kids are subject to hidden marketing: The toys are embedded with pre-programmed phrases, through which they endorse different commercial products. For example, the doll Cayla will happily talk about how much she loves different Disney movies. Meanwhile, the app-provider has a commercial relationship with Disney.


Monique Goyens, Director General of The European Consumer Organisation (BEUC), commented on these findings: “Children are especially vulnerable, and are entitled to products and services that safeguard their rights to security and privacy. As long as manufacturers are not willing to take these issues seriously it is clear that this type of connected products is not suitable for children. As an increasing number of manufacturers and providers move into the digital field, they must be careful with the security and privacy risks that the digital world opens up. With internet-connected devices gaining ground, market supervision is becoming increasingly complex. The challenge to make sure European consumers are properly protected is huge and co-operation between authorities and consumer organisations is key.”

Source : Norwegian Consumer Council Forbrukerrådet and the European Consumer Organisation BEUC

More information, the report on the terms of use and technical features