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The policy states that age assurance is handled entirely by third-party provider K-ID, with personal information for this process collected directly by K-ID and governed by K-ID's own privacy policy rather than Kick's policy.
This analysis describes what Kick'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 that age assurance data is collected and processed by K-ID under K-ID's privacy policy, removing this processing from the scope of Kick's privacy commitments. Users providing information for age assurance are subject to a separate privacy framework that Kick does not control or represent.
Interpretive note: Whether Kick's delegation of age assurance to K-ID fully satisfies Kick's regulatory obligations as a data controller depends on the applicable legal framework in each jurisdiction, which is subject to evolving regulatory guidance.
Under this clause, users undergoing age assurance provide personal information directly to K-ID, and that information is governed by K-ID's privacy policy rather than Kick's. Kick states it does not handle or process personal information in connection with age assurance.
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"In relation to age assurance processes specifically, we use an age assurance services provider, K-ID, to assist us with such processes. We do not handle or process any personal information in relation to age assurance processes, and all such information is provided directly by you to K-ID. K-ID's use of your personal information is governed by their privacy policy, which may be found at https://www.k-id.com/privacy-policy .Excerpt from Kick's Privacy Policy
1) REGULATORY LANDSCAPE: Age assurance and age verification obligations for online platforms are an active area of regulatory development in the UK under the Online Safety Act, in the EU under the Digital Services Act, and in various US states. The delegation of age assurance to a third-party provider does not necessarily transfer Kick's regulatory obligations under these frameworks to K-ID. GDPR and UK GDPR impose accountability obligations on controllers that may extend to processors and subprocessors engaged for age assurance. 2) GOVERNANCE EXPOSURE: Medium. The assertion that Kick does not handle or process personal information in relation to age assurance, and that users' information is governed solely by K-ID's privacy policy, may not fully satisfy Kick's obligations as a data controller under GDPR if Kick initiated the collection or exercises control over the purpose of age assurance processing. Regulatory guidance on delegation of age assurance obligations is evolving. 3) JURISDICTION FLAGS: UK platforms subject to the Online Safety Act and EU platforms subject to the Digital Services Act face heightened exposure regarding the adequacy of delegated age assurance mechanisms. US state laws in states such as Texas, Arkansas, and Louisiana have imposed age verification obligations on certain online platforms, with implications for third-party delegation arrangements. 4) CONTRACT AND VENDOR IMPLICATIONS: The relationship between Kick and K-ID should be reviewed to determine whether K-ID acts as a data processor under a data processing agreement, or as an independent data controller. If K-ID is a joint controller or independent controller, Kick's accountability for age assurance data processing may be limited but not eliminated under GDPR. Compliance teams should obtain and review the Kick-K-ID data processing agreement. 5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether Kick's delegation of age assurance to K-ID, with users directed to K-ID's privacy policy, satisfies transparency obligations under GDPR Article 13 and equivalent frameworks. The adequacy of K-ID's privacy policy and technical measures for the jurisdictions in which Kick operates should be independently evaluated. Kick's ability to demonstrate compliance with age assurance regulatory requirements when processing is fully delegated should be documented.
This provision establishes that age assurance data is collected and processed by K-ID under K-ID's privacy policy, removing this processing from the scope of Kick's privacy commitments. Users providing information for age assurance are subject to a separate privacy framework that Kick does not control or represent.
Under this clause, users undergoing age assurance provide personal information directly to K-ID, and that information is governed by K-ID's privacy policy rather than Kick's. Kick states it does not handle or process personal information in connection with age assurance.
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