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The policy states the Services are not intended for children and that commercially reasonable deletion efforts will be made if data from children under 13 is identified. It also provides a removal right for California residents under 18 who have posted User Input to 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
This provision establishes COPPA-related commitments regarding data collected from children under 13 and a California-specific minor content removal right under California Business and Professions Code Section 22581, while noting that removal may not be comprehensive due to third-party republication.
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 →The updated policy no longer provides a single consolidated view of which specific categories of recipients receive which types of personal data. Previously, users could see in one table that identifiers, commercial information, geolocation data, images, account credentials, and precise location were shared with specific recipient categories such as vendors, service providers, other users, login partners, social media widgets, and tracking technology providers. The revised policy instead directs users to review other sections of the document to find this information. The specificity and accessibility of this disclosure has been reduced, though the underlying data-sharing practices may remain unchanged.
View change record →Under this provision, users under 13 are not intended to use the Services, and Ideogram commits to making commercially reasonable efforts to delete data collected from children under 13 if identified. California residents under 18 may request removal of User Input they posted, though the policy states removal may not be complete due to third-party archiving and republication.
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"Our Services are not intended for children, and we do not seek or knowingly collect any personal information from children. If we become aware that we have unknowingly collected information from a child, in particular children under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. California residents under the age of 18 who have registered to use the Services and who posted User Input can request that such information be removed from the Services by contacting us at the information provided below.Excerpt from Ideogram's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates 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 policy's commercially reasonable efforts standard for deletion, rather than a more absolute obligation, may require evaluation against COPPA's requirements. The California minor content removal right references California Business and Professions Code Section 22581 (the Eraser Law). 2) GOVERNANCE EXPOSURE: Medium. The use of a commercially reasonable efforts standard for deletion of children's data, rather than an unqualified deletion obligation, may create exposure if the FTC or state regulators examine whether this standard meets COPPA requirements. The acknowledgment that removal of minor content may be incomplete due to third-party actions is consistent with California law but should be clearly communicated to requesting minors or guardians. 3) JURISDICTION FLAGS: COPPA applies federally to U.S. users under 13. California's Eraser Law applies to California minors under 18. EU member states have national age verification and parental consent requirements that may be stricter than COPPA in some jurisdictions. 4) CONTRACT AND VENDOR IMPLICATIONS: Institutional customers deploying Ideogram in contexts where minor users may be present should assess whether the platform's age verification and data deletion practices are sufficient for their own COPPA or state law compliance obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether Ideogram has operational age verification mechanisms in place, whether the commercially reasonable deletion standard is documented and implemented consistently with COPPA guidance, and whether the minor content removal process is clearly communicated to California users under 18 and their guardians.
This provision establishes COPPA-related commitments regarding data collected from children under 13 and a California-specific minor content removal right under California Business and Professions Code Section 22581, while noting that removal may not be comprehensive due to third-party republication.
Under this provision, users under 13 are not intended to use the Services, and Ideogram commits to making commercially reasonable efforts to delete data collected from children under 13 if identified. California residents under 18 may request removal of User Input they posted, though the policy states removal may not be complete due to third-party archiving and republication.
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