TickTalk 4

Warning: *privacy not included with this product

The days of being a kid free to roam and do dumb things you spend your life grateful your parents never found out about are long gone. This smart watch/tracking device/wrist communication gadget is a helicopter parent's must have accessory (OK, to be fair, I can see why parents would love this thing, it's just...kinda creepy too). Made for kids 5 -12 years old, the TickTalk watch gives parents a GPS tracking, two-way HD video and voice calling, activity tracking, photo taking, music streaming, emergency SOS calling device with a host of parental controls. It also gives parents a super creepy discreet listening function called Super Hearing. Get the app, set up the watch, strap it on your kid, and they'll never know a moment of privacy ever again. And your worry as a parent will also probably go down. This smart tracking watch for kids really does highlight the issue of privacy versus safety and how those two conflict. So, hows does the TickTalk watch do when it comes to protecting you and your kids' privacy? Well, it looks like it probably does an OK job keeping your kids' personal information private. Your personal information as a parent? Well, maybe not so much.

What could happen if something goes wrong?

There’s good news and bad news when it comes to the privacy of TickTalk's GPS location tracking, HD video and voice calling, photo taking, group chatting, activity tracking, music streaming smartwatch targeted at kids ages 5 - 12 years old. Let’s start with the bad news.

In March 2022 TickTalk got in trouble with the Children’s Advertising Review Unit (CARU) of the BBB National Programs watchdog organization when they were found to be in violation of the Children’s Online Privacy Protection Act (COPPA). That’s a lot of alphabet soup to say that a trusted watchdog organization found TickTalk didn’t provide a clear, complete, and not confusing privacy policy that let parents know about how they collect information on children. The watchdog group also found that TickTalk didn’t put their privacy policy in a prominent enough place for parents to find and, even worse, they didn’t “provide a means for parents to provide verifiable consent to its information collection practices prior to the collection of information from children.” All this is pretty bad for a device that can potentially collect so much information about a kid as young as five.

The good news is TickTalk agreed to correct these privacy violations and provided CARU a plan to do so. Which means now when you go to the TickTalk website, it’s pretty easy to find their privacy policy and that privacy policy lays out pretty clearly now things like what data is collected, when it is collected, how it is shared, and what parental consent looks like. One concern we do have about TickTalk's privacy policies -- we saw at least three different "last updated" dates on the privacy policies we tracked down from their website and app pages. That was confusing and leaves us wondering how good they still are at maintaining their privacy documentation.

So, what data does the TickTalk watch and app collect? Well, there’s two stories here. There is the data collected on your child and then there is the data collected on the parent or guardian who sets up the account for the child. When it comes to the data collected on anyone under the age of 13, well, TickTalk does seem to do OK. TickTalk can collect things like a child's name or nickname, age, gender, and birth date if you choose to share it. They can also collect location information and device information. And, they say they don’t share any of this information publicly or sell or rent it to third parties for advertising purposes. So, that’s all good.

Then there is the data TickTalk says they can collect on adults. More data is collected there. Things like name, email address, relationship to the child, location information, device information, and more. And TickTalk says they can "sell" some personal data to third parties, as that term is defined in the California Consumer Privacy Act. That's not good. Although they do go on to say, "We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age," so there's that. They do provide a way to opt-out of such data selling here.

TickTalk also says they can share your aggregated or de-identified data with partners, sponsors, or the press, for example, for things like marketing and identifying industry trends. We should remind you that it has been found to be pretty easy to re-identify some of these de-identified data sets and track down an individual’s patterns, especially when location data has been collected.

There is one specific feature on TickTalk's smartwatches for kids that really gives us the heebie jeebies. It's called Super Hearing and it is a feature that let's the owner of the TickTalk app ("full access users" as TickTalk calls them) discreetly call the smartwatch and listen in while their phone is on mute. TickTalk describes it like this, "You will be able to hear what is going on around the watch's surroundings, but your end will be muted." TickTalk also says it is was "designed solely for emergency and safety use." But yeah, we can see a bunch of ways that can be abused. Just check out the concerns this divorced mother on Reddit raised about her daughter's father spying on them in their home. Yikes!

So, what’s the worst that could happen with TickTalk? Well, anything that is designed to strap on a child as young as five, that tracks location, has two built-in cameras and a microphone, and a feature called Super Hearing that's pretty much made for spying comes with the potential for abuse and harm. It’s good to remember that. We know parents see these devices as helping protect their children from harm. We hope parents will also ask if these devices can cause harm too. Here’s hoping the smartwatch is never compromised in any way, and your child is never tracked or spied on by some bad person. That is a worst case scenario, but it’s one parents should take into consideration before buying this, or any similar device.

One final consideration. We think there is a good question to be raised about teaching young children that this level of digital surveillance in their lives is OK. Maybe we should track kids a little bit less, and teach them constant surveillance isn’t a good thing?

Tips to protect yourself

- Parents, keep a sharp eye on parent controls and permissions.
- Do not sign up with third-party accounts. Better just log in with email and strong password.
- Chose a strong password! You may use a password control tool like 1Password, KeePass etc
- Use your device privacy controls to limit access to your personal information via app (do not give access to your camera, microphone, images, location unless necessary)
- Keep your app regularly updated
- Limit ad tracking via your device (eg on iPhone go to Privacy -> Advertising -> Limit ad tracking) and biggest ad networks (for Google, go to Google account and turn off ad personalization)
- Request your data be deleted once you stop using the app. Simply deleting an app from your device usually does not erase your personal data.
- When starting a sign-up, do not agree to tracking of your data if possible.

  • mobile

Can it snoop on me? information

Camera

Device: Yes

App: Yes

Microphone

Device: Yes

App: Yes

Tracks location

Device: Yes

App: Yes

What can be used to sign up?

What data does the company collect?

How does the company use this data?

We ding this product for potentially selling the personal data of people age 16 and over to third parties according to the California Consumer Privacy Act (CCPA) definition of the term "sale".

TickTalk Privacy Policy

"We do not sell or rent any of your or your Child's Personal Information to any third party for any purpose, including for advertising or marketing. "

"TickTalk Tech LLC is the only party that can access any of your Child’s Personal Information and will never disclose, share, sell, or rent your Child’s Personal Information with any third parties, marketers, or advertisers"

"We do not use or allow third party advertisers on our children’s TickTalk smartwatches for children or our TickTalk App"

"Information collected from Children (including Personal Information and information collected automatically) is never used or disclosed for third-party advertising. Additionally, Personal Information collected from Children is never used for behaviorally-targeted advertising to Children. Lastly, Children's Personal Information is never sold or rented to anyone, including marketers or advertisers."

"Local Child Personal Information is data stored locally on your Child's TickTalk Device and is not viewable or accessible by TickTalk Tech LLC. Personal Information stored locally includes:
Child User Photo and/or Avatar as entered by the Parent ("Admin User")
Child Taken Photographs and/or Videos
Child Message Content
Child Voice Call and Video Call Records and/or Content
Child Recorded Voice Recordings
Greeting Card Content (which may contain Personal Information)
Child’s music listening trends from iHeartRadio Family including content that was listened to or favorites"

"We may use the information, including Personal Information, from adult users we collect to:
Provide and/or personalize the TickTalk Services, Website, Devices, or content and experiences for you ...
Optimize or improve the TickTalk Website, Devices, Services, and operations and develop new products
Develop and enhance our products and services with the use of aggregated data or de-identified data to use for research and development purposes provided that any disclosures of such data do not specifically identify you, your Child, your Child’s TickTalk Device, and/or your precise location ...
Combine with data from other sources outside of your use of the TickTalk Service, such as data obtained from Wi-Fi access points within range of your Child’s TickTalk Device ...
For any other purpose for which the information was collected such as fulfilling product orders"

"Aggregated Information and Non-Identifying Information: We may share aggregated information (information about our users that we combine so it no longer identifies an individual user) and other de-identified, or non-personally identifiable information with partners, sponsors, or the press to, for example, demonstrate how TickTalk Devices and/or Services are used, spot industry trends, or to provide marketing materials. Any aggregated information will not contain any identifiable Personal Information."

California Privacy Notice
"We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Commercial and Financial Information, Internet Activity, Online Identifiers, and Personal Identifiers. This allows us to show you ads that are more relevant to you.

We "sell" personal data to third parties, as that term is defined in the CCPA.You may opt-out of these data practices here.

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age."

Do Not Sell or Share My Personal Information Page
"We share personal information with third party vendors to provide more relevant, personalized ads to consumers. We also use third party data analytics providers whose collection of information may be considered a “sale” of information under some privacy laws.To opt-out of sharing and selling, submit a request below. A consumer or their authorized agent may instead submit a Request to Opt-Out via email to [email protected].

Please note that some third party vendors do not respect the U.S. Privacy String, which is the mechanism we use to communicate your Request to Opt-Out to third parties that collect information via cookies on our website. If you choose, you may also use the Digital Advertising Alliance (DAA) WebChoices Tool to globally opt-out of third-party tracking via website cookies."

"Although we make concerted good faith efforts to maintain the security of Personal Information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can't guarantee the security of information due to the inherent open nature of the Internet and wireless communications. We cannot guarantee that your personal information will be completely free from unauthorized access by third parties, such as when transferred over or through systems not within our exclusive control. Your use of the TickTalk Services demonstrates your assumption of this risk. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time. "

How can you control your data?

TickTalk Privacy Policy

"If you have registered for a Child Account on the TickTalk App, you may view, edit, or delete any of your profile information or your preferences at any time by logging into your TickTalk App account and accessing your account settings page."

"We will not retain a Child's Personal Information for any longer than is necessary to provide the Service for which we receive or collect your Child’s Personal Information, for research purposes, or legal obligations. Data is stored for one (1) year unless an account is deactivated by the Parent ("Admin User"), in which case the information will be deleted immediately. "

"Before creating a TickTalk App account, the Parent and/or Guardian will be required to submit their email address as the collection and use of data from a child will require parental consent. Parents and/or Guardians will be required to review our consent email and provide a verification code to complete their Child’s account registration. Upon receiving parental consent, Parents and/or Guardians will be able to pair with and activate their TickTalk Device for their Child. For any individuals under the age of 13 who wish to create a TickTalk App account on their personal cell phone to communicate with another Child who owns a TickTalk Device, they will be required to submit a Parent email address to receive parental consent before registering for a TickTalk App account."

"Refusing Parental Consent
If a Parent and/or Guardian refuses the collection of any Child Personal Information or data, both the Parent and/or Guardian and your Child cannot use the TickTalk Services or Devices. In this case, the Parent and/or Guardian can return the Device within thirty (30) days of purchase for a full refund.
If you have already created an account with TickTalk, the Parent and/or Guardian may delete any of your Child's Personal Information in the TickTalk App by editing directly in the TickTalk App > Settings or by contacting us at [email protected]. Additionally, at any time, you can refuse to permit us to collect further Personal Information from your Child by deleting your Child’s Account and can request that we delete the Personal Information we have collected from your Child by contacting us at [email protected]."

"We follow the Federal Trade Commission's (FTC) Children's Online Privacy Protection Act ("COPPA") rules for parental consent prior to a Parent and/or Guardian activating and setting up our Devices"

What is the company’s known track record of protecting users’ data?

Needs Improvement

In 2022, TickTalk was found to be in violation of the Children's Online Privacy Protection Act (COPPA) by the Children's Advertising Review Unit (CARU) of the BBB National Programs. The violation was due to inadequate privacy policy and because TickTalk did not give parents a way to provide verifiable consent before their child's information was collected. According to CARU. TickTalk agreed to correct their privacy violations in a detailed plan.

"The Children’s Advertising Review Unit (CARU – a children’s safety program of the US Better Business Bureau) reports that TickTalk Tech failed to meet COPPA requirements, as it didn’t provide clear, non-confusing notice of information it collects on children and it doesn’t notify parents of practices as required by COPPA."

In March 2022, TickTalk Tech LLC agreed to change its parental consent process for its child data collection practice for users of its TickTalk 4 kids smartwatch following a review from the watchdog group Children’s Advertising Review Unit (CARU). Before that, CARU review determined TickTalk did not give parents an opportunity to provide verifiable consent prior to collecting the data of children under 13 and had a privacy policy that was “confusing” and inconspicuously placed on its website.

Child Privacy Information

"We do not share your Child’s Personal Information with our subprocessors unless it has previously gone through end-to-end encryption, is unreadable by the subprocessor, and is necessary to provide our services"

Can this product be used offline?

No

User-friendly privacy information?

No

We found various privacy policies from TickTalk with confusing and contradictory "last updated" dates.

Links to privacy information

Does this product meet our Minimum Security Standards? information

Unknown

Encryption

Yes

"TickTalk Tech LLC's database where we store your Personal Information is encrypted at rest, which converts all Personal Information stored in the database to an unintelligible form."" ""Once a Child accesses their Parent-created Child Account, they can take and share photos (which may contain Personal Information) in the end-to-end encrypted Secure Messaging Center with Parent-Approved Contacts."

Strong password

Yes

Security updates

Yes

Manages vulnerabilities

Can’t Determine

We were unable to confirm if TickTalk has a way to manage security vulnerabilities like a bug bounty program.

Privacy policy

Yes

Does the product use AI? information

Can’t Determine

Is this AI untrustworthy?

Can’t Determine

What kind of decisions does the AI make about you or for you?

Is the company transparent about how the AI works?

Can’t Determine

Does the user have control over the AI features?

Can’t Determine

*privacy not included

Dive Deeper

  • Children’s Privacy: CARU finds TickTalk Tech Smart Watch & app in violation of COPPA
    CDP Institute Link opens in a new tab
  • Children’s Advertising Review Unit Finds TickTalk Tech in Violation of COPPA and CARU’s Privacy Guidelines; Company Agrees to Corrective Actions
    BBB National Programs Link opens in a new tab
  • How to Sign Into Your TickTalk App Account
    TickTalk Link opens in a new tab
  • Kids’ Smart Watchmaker Updates Privacy Practices at Safe Harbor’s Direction
    Lexology Link opens in a new tab
  • TickTalk 4 Kids Smartwatch Makers Agree To Overhaul Child Data Collection Process Following Review
    Top Class Actions Link opens in a new tab
  • The Best Smartwatches and Phones for Kids
    The New York Times Link opens in a new tab
  • The Best Smartwatches For Kids (And Parents) To Stay Connected
    Forbes Link opens in a new tab
  • Smartwatch Privacy for Kids During the Coronavirus Pandemic
    Common Sense Link opens in a new tab

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