At TickTalk, our products are designed with the goal of giving families around the world peace of mind with a device you can trust. We aim to give our customers full transparency with our products and services so you can focus on keeping your family safely connected.
The Children’s Advertising Review Unit (CARU) reached out to TickTalk after reviewing our website during routine monitoring. While CARU did not find any violations with our TickTalk 4 smartwatches or how we collect and/or use children’s information, CARU did determine that our website Privacy Policy did not “provide clear and complete, and non-confusing, notice of it’s children’s information collection practices” and that we did not “provide any notice that would constitute a direct notice [or provide verifiable consent of the information collection practices] to parents as required by COPPA [the Children’s Online Privacy Protection Act].”
Children’s safety and online privacy is extremely important to TickTalk. We are excited to be working closely with CARU to immediately resolve any concerns with our website Privacy Policy and add additional steps to gather verifiable parental notice and consent into our parental control app.
We understand that Privacy Policies and consent in technology can be confusing. We want to make sure our customers have zero doubts over our children’s information practices and detail exactly what information we collect, how we use this information, and how you, as the parent or guardian, can go about deleting or prohibiting the use of that information. We also want to make it abundantly clear that we never sell or disclose children’s information to third parties, advertisers, or marketers and we never advertise directly to children.
We want to let you, as parents and our customers, know exactly the steps we are taking to address CARU’s concerns:
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We have partnered with a FTC-approved COPPA Safe Harbor Program to confirm our policies surrounding the collection, use, maintenance, and disclosure of personal information from children under the age of 13 are consistent with COPPA. We are currently working to be not only COPPA compliant, but become fully COPPA Certified on our TickTalk 4 smartwatches and TickTalk Parental Control App as soon as possible.
*Update: As of July 2022, TickTalk's kid smart watch phones are COPPA Certified under an FTC-approved Safe Harbor Program -
We are currently reviewing and revising our Privacy Policy to give our customers complete transparency on our children’s information collection and use practices. While we had a brief breakdown of this information on our previous Privacy Policy, we are currently working with our FTC-approved COPPA Safe Harbor Program partner to revise our Privacy Policy to give our customers a complete breakdown of the information we collect and how it is used including, but not limited to, the below:
- How We Protect Children’s Personal Information
- What Information Does TickTalk Collect From Children and How It Is Used
- Child Submitted Information within our Products / Parent Created Account
- What Children’s Information is Visible to Others from the Parental Control App
- How Long Does TickTalk Keep Children’s Information
- Parental Consent & Choices
- Types of Information We Collect
- Information Provided by Parents / Approved App Users (i.e. Parent-Approved Contacts) / Customers (Purchasers of Product)
- Information Collected Automatically
- Sharing Your Information
- Transparency and Your Rights
- Accessing, Managing, or Correcting Your Personal Information
- Deleting Your Account and Information
- Object, Restrict or Withdraw Consent
- Data Security & Retention
- Integrated Services & Third-Party Services
- We are currently working on an operating system (OS) update for all TickTalk Parental Control App users that will be available for parents or guardians to download. While parents or guardians enter all their child’s information themselves while creating their child’s account and we do not auto-populate any information except for location of the device, we want parents to have clear notice of the personal information we collect from your child. Our OS update will:
- Add a means for parents to provide verifiable parental consent to our information collection practices prior to collecting any information about your child including:
- Creating a direct notice with clear, detailed information on the specific personal information we collect from your child prior to continuing to use, creating your child’s account, or activating your TickTalk smartwatch
- Sending parents a direct mechanism to provide verifiable consent outside of our TickTalk App during account registration
- Creating an age gate to request verifiable parental consent for any App Users under the age of 13
- Prompt current TickTalk Parental Control App users to re-review and provide verifiable parental consent to our Privacy Policy and Terms of Agreement before continuing to use their TickTalk device
- Allow all personal information including name or nickname, birthdate, gender, and profile picture to be optional. While this information is currently optional, we will add a disclaimer to make it unavoidably clear that it is not mandatory for you to enter your child’s personal information to use your TickTalk smartwatch
- Adding a section to our App > Settings > My App to also include our Privacy Policy for parents, guardians, and parent-approved app users to review at any time
- We immediately revised our website to address CARU’s concerns that parents or guardians could not easily find our Privacy Policy, which was previously located at the bottom of all website pages in our footer navigation bar, prior to purchasing our products including:
- Adding a prominent link to our Privacy Policy at the top of our website in the main navigation bar
- Adding a clear statement of what personal information we specifically collect from children for parents to see in our main Description section of our TickTalk 4 product page with a clear link to our Privacy Policy
- Adding a sub-section on our TickTalk 4 product page with clear information of the information we collect from children along with a direct link to our Privacy Policy
- Adding a consent box to review and agree to the Privacy Policy when Buy Now is selected on our TickTalk 4 product page prior to purchasing our products
- We are currently creating an easy-to-understand video to explain to both parents and children the details of our Privacy Policy. This video will detail what information we collect, who has access to it, how you can delete this information, and more. We will place this video on our website, Privacy Policy, Support Pages and YouTube channel for our customers to easily understand our information collection practices without having to read our Privacy Policy.
Protecting children’s online privacy and providing a safe communication device for families are our top priorities at TickTalk. We have always gone above and beyond to protect children’s information regardless of cost with using end-to-end encryption on all data transmission, partnering with one of the most secure cloud servers in the world, and handling all of our business operations internally without relying on third parties to give our customers peace of mind. As parents, we completely understand the concerns surrounding children’s online privacy and we are working swiftly to resolve any and all of CARU’s concerns.
If you have any questions or concerns, please do not hesitate to reach out to press@myticktalk.com.
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