Equifax states its websites and apps are not directed at children under 13 and that it does not knowingly collect personal information from this age group.
This analysis describes what Equifax'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
COPPA requires verifiable parental consent before collecting personal information from children under 13. However, given that Equifax holds credit and financial data about minors in certain contexts (such as authorized user accounts or identity theft protection services for families), the interaction between this disclaimer and actual data practices warrants attention.
Interpretive note: The general disclaimer does not address Equifax product lines that may involve minors' credit or identity data, creating uncertainty about the completeness of COPPA compliance disclosures in this policy.
Parents should be aware that while Equifax's consumer products are not directed at children, Equifax may hold credit-related data about minors through credit file creation for minors or family-oriented identity protection services, which may be governed by separate product-specific terms rather than this general policy.
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"Our websites and apps are not intended for individuals under the age of 13, and we do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected personal information from a child under 13, please contact us.— Excerpt from Equifax's Equifax Privacy Policy
REGULATORY LANDSCAPE: COPPA, enforced by the FTC, requires verifiable parental consent before collecting personal information from children under 13. The policy's general disclaimer is a standard COPPA compliance mechanism but may be insufficient if Equifax's products are used in contexts where minors' data is foreseeably collected. Some Equifax products, including family identity protection services, may involve processing of minors' information, which could require product-specific COPPA compliance assessments. CPRA also grants specific rights for minors under 16 with respect to sale of personal information. GOVERNANCE EXPOSURE: Low for website operations. Medium for product lines that involve family accounts or minors' credit monitoring, where COPPA compliance should be assessed at the product level rather than relying on a general policy disclaimer. JURISDICTION FLAGS: Federal COPPA applies uniformly. California's CPRA requires opt-in consent for sale of personal information of consumers under 16. Some states have enacted additional children's privacy laws that impose heightened requirements. CONTRACT AND VENDOR IMPLICATIONS: Partners offering family or minor-oriented Equifax products should be assessed for COPPA compliance obligations. Data collected about minors through any channel should be subject to enhanced access controls and separate retention policies. COMPLIANCE CONSIDERATIONS: Product teams offering family identity protection or minor credit monitoring services should conduct a COPPA compliance review separate from this general policy. Verify that age screening mechanisms are implemented where required. Assess whether any third-party tracking technologies on Equifax properties collect data in a manner that implicates COPPA.
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COPPA requires verifiable parental consent before collecting personal information from children under 13. However, given that Equifax holds credit and financial data about minors in certain contexts (such as authorized user accounts or identity theft protection services for families), the interaction between this disclaimer and actual data practices warrants attention.
Parents should be aware that while Equifax's consumer products are not directed at children, Equifax may hold credit-related data about minors through credit file creation for minors or family-oriented identity protection services, which may be governed by separate product-specific terms rather than this general policy.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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