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The policy states the service is not directed to children under 13, establishes a voluntary practice of ceasing use of data if collected from under-13 users, and provides a removal request right for users under 16 via email or certified mail.
This analysis describes what Hims & Hers'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 the company's stated compliance posture regarding minor data collection, including a voluntary removal mechanism for users under 16 and an express disclaimer that the policy does not constitute an admission of COPPA applicability, which may be relevant to FTC enforcement assessments.
Interpretive note: Whether COPPA applies to the acne consultation service for minors 13 to 18 depends on whether that service constitutes actual knowledge of minor data collection under the FTC's interpretation, which is a fact-specific assessment not determinable from the policy text alone.
The agreement establishes that users under 16 may request removal of content or information posted about them on the platform by submitting a written request to privacy@forhims.com or by certified mail to the Privacy Officer. The policy specifies exceptions where removal may not be required, including where data is part of a medical record maintained on behalf of healthcare providers.
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"The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form. Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal guardian if you are under age 13) may at any time request that we remove content or information about you that is posted on the Platform.Excerpt from Hims & Hers's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA) and the FTC's COPPA Rule, which apply to online services directed to children under 13 or where the operator has actual knowledge of collecting personal information from children under 13. The company's express disclaimer that its practices do not constitute admission of COPPA applicability is a standard protective legal statement but does not alter the FTC's analysis of whether COPPA applies based on the service's content, audience, and actual knowledge standard. California's minor data privacy provisions, including those applicable to users under 16, also engage this provision. 2. GOVERNANCE EXPOSURE: Medium. The service's telehealth and wellness functions and the provision authorizing minors between 13 and 18 to use the service for acne consultations with parental consent creates actual knowledge of minor user data collection in those contexts, which may trigger COPPA and applicable state minor privacy law obligations for those users. The medical record retention exception to the removal obligation may interact with state minor medical privacy rights. 3. JURISDICTION FLAGS: California's eraser law and similar provisions in other states may impose minor data removal obligations beyond those described in this policy. The policy's removal mechanism specifies exceptions that may not be available under all applicable state minor privacy frameworks. The medical record maintenance exception may be subject to state minor medical privacy statutes that grant minors independent rights to their medical records upon reaching specified ages. 4. CONTRACT AND VENDOR IMPLICATIONS: If third-party advertising or analytics vendors receive data from the platform through cookie or pixel integrations, and that data includes data from minor users who access acne consultation services, those data flows should be assessed for COPPA compliance and applicable state minor data protection requirements. 5. COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the acne consultation service for minors 13 to 18 with parental consent constitutes actual knowledge of minor data collection triggering COPPA obligations for those users; confirm that parental consent mechanisms meet COPPA and applicable state requirements; review whether advertising partner data flows exclude data from identified minor users; and assess whether the removal exception for medical records maintained on behalf of providers is consistent with applicable state minor medical privacy statutes.
This provision establishes the company's stated compliance posture regarding minor data collection, including a voluntary removal mechanism for users under 16 and an express disclaimer that the policy does not constitute an admission of COPPA applicability, which may be relevant to FTC enforcement assessments.
The agreement establishes that users under 16 may request removal of content or information posted about them on the platform by submitting a written request to privacy@forhims.com or by certified mail to the Privacy Officer. The policy specifies exceptions where removal may not be required, including where data is part of a medical record maintained on behalf of healthcare providers.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Hims & Hers.