Activision states it does not intentionally collect data from children under 13 without parental consent, and will delete such data if discovered, but parents need to proactively contact Activision to protect their child's data.
This analysis describes what Activision's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Given that many Activision games are played by children and teenagers, the adequacy of age verification and parental consent mechanisms has significant legal and safety implications under COPPA in the US and the GDPR's protections for minors.
Interpretive note: The policy does not describe the specific age verification mechanism used, making it difficult to assess whether the 'knowingly collect' standard satisfies current FTC and ICO expectations for proactive rather than reactive compliance.
Parents of children under 13 should be aware that while Activision states it will delete inadvertently collected children's data, the burden of identifying and requesting deletion falls on parents, and the policy acknowledges that underage data may be collected before detection.
How other platforms handle this
Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected personal information from a child under the age of 13 without parental consent, we wil...
Our online services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible.
Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without parental consent, we will take steps to delete such information. In some juris...
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"We do not knowingly collect personal information from children under 13 without verifiable parental consent. If we become aware that a child under 13 has provided personal information without parental consent, we will delete such information. Parents or legal guardians may contact us to review, update, or delete their child's personal information.— Excerpt from Activision's Activision Privacy Policy
(1) REGULATORY LANDSCAPE: COPPA (Children's Online Privacy Protection Act) requires verifiable parental consent before collecting personal information from US children under 13, enforced by the FTC. The policy's 'knowingly collect' standard aligns with COPPA's language but the adequacy of Activision's age verification mechanisms is not described in the policy. GDPR Article 8 sets consent age thresholds for data processing (13-16 depending on member state). The UK Children's Code (Age Appropriate Design Code) imposes additional obligations for services likely to be accessed by under-18s in the UK. (2) GOVERNANCE EXPOSURE: High. Gaming platforms have historically been a focus of FTC COPPA enforcement actions. The policy's reliance on post-hoc deletion rather than proactive age-gating creates enforcement exposure, particularly where games are ESRB-rated for teens or adults but remain accessible to younger players. (3) JURISDICTION FLAGS: US (COPPA/FTC), EU member states with age of consent below 16 under GDPR Article 8, and the UK (Children's Code enforced by ICO) create the highest exposure. California's Age-Appropriate Design Code Act (AADC), if operative, would impose additional design-level protections for minors accessing Activision services. (4) CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising and analytics partners receiving data must be contractually restricted from processing data attributable to users under 13 (or applicable age threshold) under both COPPA and GDPR. Data processing agreements should include representations and warranties about handling of minors' data. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether current age verification mechanisms meet FTC COPPA guidance and UK ICO Children's Code standards, whether targeted advertising is disabled for accounts identified as minors, and whether data minimization practices are applied to younger user cohorts. Parents should be provided a clear and accessible mechanism to submit deletion requests.
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Given that many Activision games are played by children and teenagers, the adequacy of age verification and parental consent mechanisms has significant legal and safety implications under COPPA in the US and the GDPR's protections for minors.
Parents of children under 13 should be aware that while Activision states it will delete inadvertently collected children's data, the burden of identifying and requesting deletion falls on parents, and the policy acknowledges that underage data may be collected before detection.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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