Gemini's services are not available to anyone under 18 years old, and anyone under that age should not use the platform or provide their personal information.
This analysis describes what Gemini'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 establishes an age minimum and signals that Gemini does not intend to collect data from minors, which is consistent with COPPA requirements for online services directed at children or with actual knowledge of children's data.
Users under 18 are excluded from Gemini's services, and if a minor's data is inadvertently collected, the policy establishes the company's position that this was not intended. Parents or guardians should be aware that minors should not create accounts.
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At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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.
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"If you do not wish your Personal Information collected, used, or disclosed as described below, or if you are under the age of 18, you should stop accessing our Services.— Excerpt from Gemini's Gemini Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages COPPA (Children's Online Privacy Protection Act), which applies to online services directed to children under 13 or that have actual knowledge they are collecting data from children under 13. The 18-year age threshold is stricter than COPPA's 13-year threshold, likely reflecting both financial services regulatory requirements (KYC/AML obligations requiring adult account holders) and broader risk management. State laws including California's AADC and similar minor-protective statutes may also be relevant. (2) GOVERNANCE EXPOSURE: Low for COPPA purposes given the 18-year threshold exceeds COPPA's 13-year minimum. However, the policy does not describe technical age verification mechanisms beyond self-attestation, which creates residual risk if minors access the platform despite the stated restriction. (3) JURISDICTION FLAGS: California's Age Appropriate Design Code (AADC, AB 2273) imposes additional obligations for services that minors may access even if not directed at them, which may require Gemini to assess the likelihood of minor access and implement privacy protections accordingly. (4) CONTRACT AND VENDOR IMPLICATIONS: No significant B2B or vendor implications specific to this provision beyond ensuring that identity verification vendors used for KYC confirm age as part of onboarding. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether Gemini's identity verification process reliably excludes users under 18, and whether the policy adequately addresses the handling of data if a minor's account is discovered post-creation.
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This provision establishes an age minimum and signals that Gemini does not intend to collect data from minors, which is consistent with COPPA requirements for online services directed at children or with actual knowledge of children's data.
Users under 18 are excluded from Gemini's services, and if a minor's data is inadvertently collected, the policy establishes the company's position that this was not intended. Parents or guardians should be aware that minors should not create accounts.
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