Children's Data Policy (COPPA-Aligned)

What it is

The policy states Kick's services are not directed to children under 13, that Kick does not knowingly collect personal information from this age group, and that upon learning of such collection Kick will promptly delete the information.

Why it matters (compliance & governance perspective)

This provision establishes a COPPA-aligned age threshold and a reactive deletion commitment for data collected from children under 13. The policy relies on the age assurance mechanism (delegated to K-ID) and user self-representation as the primary gatekeeping mechanisms, rather than describing a verified parental consent process.

Consumer impact (what this means for users)

Under this provision, children under 13 are not intended to use Kick's services, and parents or guardians who believe a child has submitted personal information may contact Kick to request deletion. The agreement states that upon learning of data collection from a child under 13, Kick will promptly delete that information.

What you can do

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The Children's Online Privacy Protection Act (COPPA) in the United States requires operators of online services not directed to children under 13 to refrain from knowingly collecting personal information from that age group and to provide a mechanism for parental deletion requests. The policy's language mirrors COPPA's 'not directed to' standard. In the EU and UK, the GDPR and UK GDPR establish child-specific protections, and the UK Age Appropriate Design Code imposes additional obligations on services likely to be accessed by children. 2) GOVERNANCE EXPOSURE: Medium. The policy's reliance on a reactive deletion process and delegation of age assurance to K-ID raises questions about the proactive safeguards in place to prevent collection from under-13 users, particularly on a gaming livestreaming platform that may be accessed by minors. The FTC enforces COPPA and has brought enforcement actions against platforms that failed to implement adequate safeguards despite 'not directed to children' disclaimers. 3) JURISDICTION FLAGS: US operators subject to COPPA face heightened exposure if the platform is accessible to under-13 users. UK platforms subject to the Age Appropriate Design Code face obligations that go beyond reactive deletion, including default privacy settings and proactive age estimation. EU member states may impose additional child protection requirements under GDPR Article 8 and national implementing legislation. 4) CONTRACT AND VENDOR IMPLICATIONS: The delegation of age assurance to K-ID should be reviewed to confirm that K-ID's processes meet the verification standards required under COPPA and the UK Age Appropriate Design Code for the relevant service context. 5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the combination of K-ID's age assurance and the reactive deletion policy constitutes a sufficient COPPA compliance program, particularly given the FTC's evolving guidance on age verification. The UK Age Appropriate Design Code compliance assessment should be conducted separately, as it imposes proactive design obligations beyond data deletion.

Applicable agencies

Provision details

Other risks in this policy

• Mandatory service-related email communications cannot be unsubscribed medium
• Children under 13 prohibited from using Services high
• Government ID collection before creator cashout high
• Kick not liable for loss due to user failure to protect credentials high
• K-ID handles age assurance data directly high
• Payment processing via third-party processors only high