The notice includes a section addressing children's personal information, which is standard for consumer-facing services in the United States subject to COPPA.
This analysis describes what Cash App'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
This provision operationalizes Cash App's compliance with the Children's Online Privacy Protection Act (COPPA) and establishes the procedural mechanism for handling inadvertent collection of children's data. The clause defines the company's data handling obligations when minors are involved and specifies remedial action upon discovery.
Interpretive note: The specific language and protections in the children's personal information section were referenced but not fully extracted in the available document text, so the adequacy of COPPA compliance described therein cannot be fully assessed.
The updated policy establishes that children under 13 may use Cash App services if a parent or guardian signs up for or authorizes the account on their behalf. Previously, the policy explicitly prohibited any use by children under 13. The revised language clarifies that data deletion obligations apply when Cash App learns an account belongs to an unauthorized child under 13, but does not specify what happens to data from authorized child accounts or how parental oversight operates. A separate Privacy Notice for Children is referenced but not included in the change summary.
View change record →The revised policy shifts from prohibiting all children under 13 from using Cash App to permitting use when a parent or guardian explicitly authorizes or signs up for the service on the child's behalf. This creates a new lawful use path for families, but also establishes a distinction between authorized and unauthorized child accounts. The policy states that if a child under 13 operates an unauthorized account, Cash App will delete collected data upon discovery. Parents or guardians who authorize services should review the new Privacy Notice for Children for details on how child data is processed.
View change record →The updated terms state that children under 13 can no longer use Cash App, eliminating a path that previously existed for parents to authorize accounts on behalf of younger children. The revised language no longer references a separate Privacy Notice for Children, consolidating all child data handling disclosures into the main policy. If Cash App collects data and later learns it came from a child under 13, the policy requires deletion of that data, though the updated language broadens this obligation by removing the phrase 'for an unauthorized account', potentially extending deletion requirements beyond accounts that were never authorized.
View change record →The notice includes provisions addressing children's personal information; parents or guardians who believe a minor's data has been collected through Cash App should review the children's section of the notice and contact Cash App to request deletion of that data.
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"Children's Personal Information— Excerpt from Cash App's Cash App Privacy Policy
1) REGULATORY LANDSCAPE: COPPA, enforced by the FTC, imposes strict requirements on the collection of personal information from children under 13, including verifiable parental consent requirements, data minimization, and deletion rights. COPPA applies to online services directed to children or with actual knowledge of collection from children under 13. The FTC has taken enforcement action against financial services applications that collected data from minors without appropriate consent mechanisms. 2) GOVERNANCE EXPOSURE: Medium. The inclusion of a children's personal information section indicates awareness of COPPA obligations, but the adequacy of the described protections depends on the specific language in that section, which was referenced but not fully extracted in the available document text. Financial services applications face heightened COPPA scrutiny if age verification mechanisms are insufficient. 3) JURISDICTION FLAGS: COPPA applies federally to all US users under 13. Several states including California (COPPA-plus protections under the California Age-Appropriate Design Code) and New York have enacted or proposed children's privacy laws that impose additional obligations beyond federal COPPA requirements. 4) CONTRACT AND VENDOR IMPLICATIONS: Service providers and vendors who process data on behalf of Cash App where children's data may be involved must be assessed for COPPA compliance. Third-party advertising partners who receive data from Cash App's platform should be contractually restricted from using that data in connection with known children's data. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should review the specific language in the children's personal information section to confirm COPPA compliance, including age verification mechanisms, parental consent procedures, and data deletion rights for minors. The California Age-Appropriate Design Code should be assessed for applicability to Cash App's services.
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This provision operationalizes Cash App's compliance with the Children's Online Privacy Protection Act (COPPA) and establishes the procedural mechanism for handling inadvertent collection of children's data. The clause defines the company's data handling obligations when minors are involved and specifies remedial action upon discovery.
The notice includes provisions addressing children's personal information; parents or guardians who believe a minor's data has been collected through Cash App should review the children's section of the notice and contact Cash App to request deletion of that data.
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