ANALYSIS (no court or agency has ruled)
This is the plain-language version of the cited update, written to be read out loud. No judge or government agency has decided any of this, and everyone named is presumed to have acted lawfully.
There is a federal law about collecting personal information from children on the internet. Here is the strange part: Bricks & Minifigs clearly knows the law exists, because it wrote a whole section about it into the rules of one of its giveaways. It just did not put that same care anywhere its stores actually take children’s information.
One of the company’s online sweepstakes has a section in its official rules headed “Age Verification & COPPA Compliance.” It says the contest is for adults eighteen and older, that the company does not knowingly collect information from anyone under thirteen, and that if a parent tells them a child entered, they will delete it. That is a real children’s-privacy notice, written on purpose. So the company knows this area of law, and it knows how to write the warning. It put that warning on a one-time contest. It did not put it on the rewards club, on the birthday-party booking, or in the privacy policy on its store websites.
You do not have to guess who the customer is, because the company already told its own owners. Its operations manual, which this site has already published, says to keep the store bathroom stocked with diapers and a step stool because, in its words, “we will have a lot of children in our stores,” and it calls the child “the conduit to the parents” the store buys from. The storefronts match. You book a birthday party online and pay a deposit up front, for kids the party pages list as ages five and up. The rewards club is free, the company tells you to share it “with the whole family,” and it saves a birthday so it can send you a reward on the day. Toys, parties, a build bar, a little figure a kid puts together to take home. This is a place made for children, by the company’s own description of it.
The privacy policy on the store websites says the reverse of the manual. It says the site “is not intended for children under 13,” that no one under thirteen should hand over any personal information, and that the company “does not knowingly collect” it. That same wording sits on store after store, one updated back in 2019, one in 2021, and one just five days before this was written. The company’s main corporate privacy policy, last touched in 2019, does not mention children at all, except to warn that some sets have small parts unsafe for kids under three. So a business that plans for a lot of children tells you, in the one document that governs their information, that the children are not there.
The children’s privacy law, which the Federal Trade Commission enforces, says that if you collect personal information online from a child under thirteen, you have to tell the parent and get the parent’s permission first. It applies two ways: if your service is aimed at children, or if you simply know you are collecting a child’s information. Nobody found a parental-permission step on the rewards signup, on the party booking, or anywhere on the store sites. And the word carrying all the weight in “we do not knowingly collect” is “knowingly.” You know a child’s information when a party booking names a child of a given age, or a rewards account is built around a birthday. The government has treated a birthday typed into a signup as exactly that kind of knowledge: in 2023 it made Microsoft pay twenty million dollars over claims that the Xbox signup collected kids’ information, including their age, before a parent was ever asked. The year the company mislabeled kids’ videos, Disney paid ten million. The fines are counted per child, up to about fifty-three thousand dollars each. Whether a store like this counts as “aimed at children” is the harder, arguable part, and this site is not saying the line has been crossed. It is setting the company’s own documents down next to the law and letting you see how short the distance is.
To be fair, and it matters: no court or agency has found that Bricks & Minifigs broke this law, and this site is not saying it did. Selling to families is completely legal, and plenty of stores do it. A birthday box on a rewards form is ordinary. The “not intended for children under 13” line is a stock sentence that comes pre-loaded in a lot of online store templates, so its being there does not prove much on its own. Whether these sites really count as aimed at children, when a lot of the buyers are adult collectors and parents, is a genuine question that only the government can answer case by case. And a company can decide in good faith that a particular page does not trip the rule. The point of the piece is not a verdict. It is that the documents are public, and they do not line up.
This is a plain-language retelling. The exact quotes, the links to every document, and the law itself are in the full update. Nothing here is a finding of law.
The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the criminal charges referenced are unadjudicated and every defendant is presumed innocent. Sources are linked so readers can check the record. · Home · Map · The law · Bodycam