Illegal Data Collection on Kids by App Stores

By Thomas Vink, 17th September 2025

With the support of the 5Rights Foundation, Good Law Project made a submission in May 2025 to the UK Competition and Markets Authority (CMA) against Apple and Google app stores for monopolistic behaviour.

The complaint focuses on how these stores fail to inform and enforce the legal requirements around app ratings, allowing downloaded apps to process children’s data for surveillance advertising purposes. At present, apps face no consequences for carrying out extensive data processing and sharing because it does not impact the number of downloads.

Illegal data collection on kids by App stores

Organisation Name

5Rights Foundation and Good Law Project

Country/Jurisdiction

United Kingdom

Grant Amount

EUR 40,000

Current Status

Ongoing

Image credit: Photo by James Yarema on Unsplash

Grant type

Litigation Track Support

Description

With the support of the 5Rights Foundation, Good Law Project made a submission in May 2025 to the UK Competition and Markets Authority (CMA) against Apple and Google app stores for monopolistic behaviour.

The complaint focuses on how these stores fail to inform and enforce the legal requirements around app ratings, allowing downloaded apps to process children’s data for surveillance advertising purposes. At present, apps face no consequences for carrying out extensive data processing and sharing because it does not impact the number of downloads.

The CMA has existing powers to:

  1. impose a financial penalty on entities of up to 10% of their global annual revenue;
  2. accept and impose commitments from entities on market practices and structure; and,
  3. order companies to stop the harmful behaviour.

Good Law Project plans to seek a material fine, subject to demonstrating harm, and obtain directions and/or commitments to change these abusive market practices and provide greater protection for children online. An adverse decision against Google and Apple would also enable follow-on claims, increasing commercial pressure on the gatekeepers to come to the table and resolve the issue.

"these stores fail to inform and enforce the legal requirements around app ratings, allowing downloaded apps to process children’s data for surveillance advertising purposes"

Strategic Goals

App stores stop allowing users to download an app when they know the user does not meet the specific age requirements set by the app themselves, and app developers reduce their reliance on extractive and problematic data practices, leading to less data processing and sharing.

Organisation Name

Women’s Link Worldwide