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Privacy Tip #458 – FTC Alleges Robot Toy Maker Allows Third Party in China to Collect Children’s Geolocation Data
Thursday, September 4, 2025

On September 3, 2025, the Department of Justice (DOJ) filed suit against Apitor Technology, which makes robotic toys, alleging that Apitor’s app “enabled a third party in China to collect geolocation information from children without parental consent.”

The DOJ filed suit following a referral from the Federal Trade Commission (FTC) that Apitor did not comply with the Children’s Online Privacy Protection Act (COPPA) because it failed to obtain parental consent before collecting geolocation data from children, and allowed a third party in China to collect children’s geolocation data without parental consent.

Apitor, based in China, “sells robot toys targeted to children ages 6-14 and includes a free companion mobile app that allows users to program and control the toys.” The complaint alleges that users with Android devices are required to enable location sharing to use the app. There is no ability to only enable location services while using the app. This means that the app has access to the geolocation of the user even when not using the toy. In addition, Apitor integrated a third party software development called JPush in the app that allowed JPush’s developers access to the geolocation data for any purpose. As soon as the app is downloaded to an Android device, JPush has access to users’ precise geolocation data without the children or their parent’s knowledge. The DOJ alleges that Apitor failed to notify parents that JPush was collecting and using geolocation information.

The proposed order requires Apitor to ensure that any third-party software it uses is in compliance with the COPPA Rule, a proposed $500,000 penalty, notification to parents before Apitor collects or permits a third-party to collect personal information of children under the age of 13, deletion of a child’s personal information at the request of a parent, and only retaining personal information for as long as is reasonably necessary. The complaint shows the importance of understanding what data apps are collecting when they are downloaded, especially when the app is used by children. Consider researching the app before you download it, including reading the Privacy Policy and Terms of Use. Be wary of apps that are owned by companies that are located in other countries, particularly countries that are considered threats to national security such as China, Russia, North Korea, and Iran. Understand when apps are collecting geolocation and try to limit the sharing to just when they are being used. For more information, check out Privacy Tip #293 that highlights considerations for downloading apps with location based services.

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