ElevenLabs does not intentionally collect data from children under 13, and will delete such data if discovered, but relies on self-reported age rather than active verification.
This analysis describes what ElevenLabs'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
Age verification practices for voice AI platforms are under increasing regulatory scrutiny, and a policy relying on 'knowing' collection without active verification may not fully satisfy COPPA obligations in practice.
Interpretive note: COPPA compliance depends on the adequacy of the platform's age verification implementation, which cannot be assessed from the policy text alone; the 'knowingly collect' standard's practical application depends on platform design and audience characteristics.
Parents should be aware that ElevenLabs' age restriction relies on disclosure and post-discovery deletion rather than active age verification, which means a child could submit voice data before the company becomes aware of their age.
How other platforms handle this
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
Our Services are not directed to children under 13. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us at privacy@medium.com.
To access and use the Services, you must be at least the age of majority in the state, province, or territory where you live or at least 18 years of age. If you are under the age of 13, you may not use the Services and you should not be visiting the Sites or using the Services.
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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 ElevenLabs's ElevenLabs Privacy Policy
REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The FTC has taken enforcement action against platforms that failed to implement adequate age verification. In the EU, GDPR Article 8 sets the age of digital consent at 16 (with member states permitted to lower this to 13), and children's data receives heightened protection. GOVERNANCE EXPOSURE: Medium. A platform that collects voice recordings — which could constitute biometric data — from users without active age verification creates COPPA exposure if children access the service. The 'knowingly collect' standard in COPPA has been interpreted broadly by the FTC to encompass constructive knowledge based on platform design and audience signals. JURISDICTION FLAGS: US federal COPPA jurisdiction applies to all child users. EU member states have varying ages of digital consent (13-16). California's AADC (Age-Appropriate Design Code), modeled on the UK's equivalent, imposes additional design obligations for services likely to be accessed by minors. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers deploying ElevenLabs in contexts where minors may be users (educational, consumer-facing) should ensure their own COPPA compliance programs address the downstream voice data collection and that their contracts with ElevenLabs specify obligations regarding child data. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether ElevenLabs' platform design includes any signals that would attract child users and whether those signals trigger heightened COPPA obligations. The policy's deletion commitment upon discovery should be operationalized with a defined internal process and timeline. GDPR Article 8 compliance should be confirmed for EU-facing services.
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Age verification practices for voice AI platforms are under increasing regulatory scrutiny, and a policy relying on 'knowing' collection without active verification may not fully satisfy COPPA obligations in practice.
Parents should be aware that ElevenLabs' age restriction relies on disclosure and post-discovery deletion rather than active age verification, which means a child could submit voice data before the company becomes aware of their age.
ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.
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