Chegg says its services are not for children under 13 and that it will delete data if it discovers it was collected from a child under 13 without parental consent.
This analysis describes what Chegg'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 Chegg is an education platform heavily used by teenagers including students under 13, the adequacy of the age verification mechanism and the reactive rather than proactive approach to underage data collection creates meaningful COPPA risk.
Interpretive note: Whether Chegg's reactive deletion approach satisfies COPPA depends on whether the service is directed to children within the meaning of the statute and whether actual knowledge of underage users can be imputed; this is a fact-specific inquiry subject to FTC interpretation.
The policy's reliance on a reactive deletion approach rather than proactive age verification may not adequately protect children under 13 who access the platform, creating COPPA exposure and potential risk that underage users' data is collected and shared with advertising partners before detection.
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"Our 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 become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information.— Excerpt from Chegg's Chegg Privacy Policy
(1) REGULATORY LANDSCAPE: COPPA requires verifiable parental consent before collecting personal information from children under 13; the FTC is the primary enforcement authority and has brought significant enforcement actions against platforms that knowingly collect children's data without adequate consent mechanisms. The policy's standard disclaimer without description of active age verification mechanisms may not satisfy COPPA's requirements if the platform is accessible to and used by children. (2) GOVERNANCE EXPOSURE: High. Chegg's platform is widely used by students including high school and middle school students, creating a realistic risk that users under 13 access the service; a reactive deletion policy without proactive age gating may not satisfy COPPA's actual knowledge or directed-to-children standards, particularly if the platform's content or marketing appeals to younger students. (3) JURISDICTION FLAGS: COPPA applies federally for all US users under 13; in the EU, GDPR requires that consent for children under 16 (or a lower age set by member states, with a minimum of 13) be given or authorized by a parent or guardian. Several US states have enacted additional children's online privacy laws, including California's Age-Appropriate Design Code, which may impose stricter requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: If Chegg partners with schools or educational institutions that enroll students under 13, those institutional relationships may transfer FERPA and COPPA obligations; procurement teams at educational institutions should evaluate whether Chegg's data practices are compatible with their COPPA consent obligations under the school consent exception. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the current age verification mechanism is operationally sufficient to prevent collection of data from users under 13; the California Age-Appropriate Design Code may require additional default privacy protections for users under 18 regardless of COPPA thresholds; the policy should be reviewed against COPPA safe harbor program requirements if Chegg participates in such a program.
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Given that Chegg is an education platform heavily used by teenagers including students under 13, the adequacy of the age verification mechanism and the reactive rather than proactive approach to underage data collection creates meaningful COPPA risk.
The policy's reliance on a reactive deletion approach rather than proactive age verification may not adequately protect children under 13 who access the platform, creating COPPA exposure and potential risk that underage users' data is collected and shared with advertising partners before detection.
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