Ideogram's service is not intended for children under 13, and the company says it will delete data if it discovers a child under 13 has used the platform.
This analysis describes what Ideogram'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
The policy relies on a reactive rather than proactive age verification approach, meaning children's data may be collected before the company becomes aware of a violation, which is a common but operationally limited approach to COPPA compliance.
The updated policy now provides explicit disclosure of which categories of personal information are collected and which parties receive each category. Previously, the policy required readers to consult other sections to identify this information. The updated table format discloses that identifiers such as name and email address, visual information including uploaded images, and geolocation data may be shared with other users, vendors, service providers, login integration partners, social media widgets, and affiliates. This change provides clearer visibility into data sharing practices without altering what data is collected or shared, but rather how that information is disclosed.
View change record →If a child under 13 uses Ideogram and the company discovers this, the policy states it will delete the data, but there is no described mechanism to prevent children from signing up in the first place.
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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...
enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }
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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 learn that we have collected personal information from a child under 13, we will take steps to delete such information as soon as possible.— Excerpt from Ideogram's Ideogram Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which prohibits collecting personal information from children under 13 without verifiable parental consent. The EU's GDPR sets a digital consent age of 16 (or lower as set by member states, with a minimum of 13), and GDPR Article 8 requires member state-specific consent mechanisms for children. The UK's Age Appropriate Design Code (Children's Code) imposes additional design obligations for services likely to be accessed by children under 18. (2) GOVERNANCE EXPOSURE: Medium. The policy's reactive approach to COPPA compliance, relying on post-hoc discovery rather than proactive age verification, is common but creates regulatory exposure if the service is accessed by children under 13. AI image generation platforms may attract younger users, increasing the practical risk. (3) JURISDICTION FLAGS: US-based enforcement under COPPA applies globally to operators targeting US users. EU member states with a digital consent age above 13 create additional exposure. The UK Children's Code applies if the service is likely to be accessed by UK users under 18. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise and educational customers should confirm that Ideogram is not deployed in contexts accessible to children under 13 without appropriate safeguards, as COPPA liability may extend to operators who knowingly facilitate such access. (5) COMPLIANCE CONSIDERATIONS: Evaluate whether the service's user base and marketing practices create actual knowledge of access by children under 13, which would trigger COPPA obligations. Consider whether proactive age verification mechanisms are warranted given the nature of an AI image generation platform. Review compliance with EU member state digital consent ages for users below 16.
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The policy relies on a reactive rather than proactive age verification approach, meaning children's data may be collected before the company becomes aware of a violation, which is a common but operationally limited approach to COPPA compliance.
If a child under 13 uses Ideogram and the company discovers this, the policy states it will delete the data, but there is no described mechanism to prevent children from signing up in the first place.
ConductAtlas has identified this type of provision across 26 platforms. See the full comparison.
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