The policy states that Instacart's services are not directed to children under 18, and Instacart does not knowingly collect personal information from minors.
This analysis describes what Instacart'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
Setting the age threshold at 18 rather than 13 (the COPPA threshold) means the policy asserts a higher minimum age for service use, which affects how accounts created by users under 18 are treated and what rights apply to their data.
Interpretive note: The full text of the Children's Privacy section was not included in the provided document excerpt; the age threshold and specific handling terms are inferred from the section heading and common policy structures.
The policy's age restriction at 18 rather than the COPPA threshold of 13 means that teenagers between 13 and 17 are not the intended user group; parents and guardians of minors should be aware that accounts created by users under 18 may be subject to data deletion upon discovery.
How other platforms handle this
Our Services are not directed to children under the age of 13. 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 without parental consent, we will take steps to delete such information. In some juris...
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 become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information.
The Waze App is not intended for use by children. We do not knowingly collect personal information from children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be higher, such as 16 in certain EU member states). If we become aware that we have collected...
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"Children's Privacy— Excerpt from Instacart's Instacart Privacy Policy
REGULATORY LANDSCAPE: COPPA, enforced by the FTC, applies to online services directed to children under 13 or that knowingly collect personal information from children under 13. By setting the age threshold at 18, Instacart's policy is more restrictive than COPPA's minimum but does not engage COPPA's parental consent requirements for the 13-17 cohort. State laws such as California's Age Appropriate Design Code Act may impose additional obligations for services likely accessed by minors. GOVERNANCE EXPOSURE: Medium. If Instacart discovers accounts belonging to users under 18, the policy implies deletion of associated data, but the enforcement mechanism is not specified. Failure to identify and remove minor accounts when discovered could create regulatory exposure under state laws. JURISDICTION FLAGS: California's Age Appropriate Design Code Act (if currently enforceable following litigation) would require privacy-protective defaults and data minimization for services likely accessed by minors. Similar laws in other states may apply. The UK Age Appropriate Design Code is not applicable to U.S.-only services but is relevant for any UK-facing operations. CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising and analytics partners receiving data from Instacart should be contractually restricted from using data associated with accounts later identified as belonging to minors. This is a standard due diligence item in advertising technology vendor assessments. COMPLIANCE CONSIDERATIONS: Teams should review age verification mechanisms (if any) to assess whether they are sufficient to support the 18-and-over policy claim; evaluate whether advertising targeting exclusions apply to accounts in age-ambiguous categories; and monitor state-level children's privacy legislative developments that may impose additional obligations.
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Setting the age threshold at 18 rather than 13 (the COPPA threshold) means the policy asserts a higher minimum age for service use, which affects how accounts created by users under 18 are treated and what rights apply to their data.
The policy's age restriction at 18 rather than the COPPA threshold of 13 means that teenagers between 13 and 17 are not the intended user group; parents and guardians of minors should be aware that accounts created by users under 18 may be subject to data deletion upon discovery.
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