As information society members, we are experiencing the massive phenomenon of the rise of domestic Internet-connected devices (knows as the “Internet of Things” or “IoT”). Among these new connected objects are also Internet-connected toys. E-toys represent important opportunities to play, learning, health and educational support. However, they also raise concerns about safety, privacy, security, and trust.

Smart toys are “hybrid products” where the customer owns the physical object while toy embedded software exposes the user to long-term contractual obligations. Such contractual conditions imply data exchange between the child and the platform; the child and the parent; and the child and other third-party data recipients. 

It is relevant to distinguish between “smart toys” and “connected toys”. The former are entertainment devices including microphone, camera, sensors, gyroscope, and other features. However, these toys are not necessarily connected to the Internet. Contrarily, connected toys are designed to connect to the Internet and related servers that process personal data and empower toy intelligence. These toys have the capacity to record a great array of data such as sounds, images, movements, and heartbeat. “Play Data” are any data that can be recorded while the user plays is playing while the toy retains a memory of the user’s play and its evolution. 

1. Play Data helps the toy to engage more emotionally with the child while providing him feedback to improve skills and abilities;
2. Play Data allow feedback to be provided to parents, teachers that have the chance to track toys child usage;
3. The connected toy may share play data or other personal data such as name, age, email address, postal address, and localisation.

In such context, recital 38 of GDPR states that children require specific protection with regard to their personal data. Such specific protection shall apply to the use of personal data of children for the purposes of marketing or the collection of personal data with when children use services or products offered directly to them. Under these circumstances, it results that connected toys may jeopardise children right to privacy.

In conclusion, the datafication of children raises numerous concerns. In fact, children growing up in a culture of self-surveillance and self-tracking is likely to shape children future life.  

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