Lime states its services are not for users under 18 and says it will delete data if it discovers it was collected from a minor.
This analysis describes what Lime'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 sets the age threshold at 18 rather than the COPPA standard of 13, which is a more protective approach for minors, but the enforcement mechanism relies on Lime discovering the collection rather than proactive age verification.
Interpretive note: The document does not describe what technical measures are used to verify user age at registration, making it unclear whether the 18+ restriction is effectively enforced in practice.
Lime's stated policy restricts service use to users 18 and older and commits to deleting data collected from users under 18, though the policy does not describe what technical or procedural measures are used to verify user age at account creation.
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Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected personal information from a child under the age of 13 without parental consent, we wil...
Our online 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 delete that information as quickly as possible.
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...
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"Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information of a child under 18, we will take steps to delete such information as soon as possible.— Excerpt from Lime's Lime Privacy Policy
REGULATORY LANDSCAPE: Children's data collection engages COPPA (Children's Online Privacy Protection Act, enforced by the FTC) for US users under 13, and GDPR Article 8 for EU users (age of digital consent varies by member state from 13-16). Lime's 18+ threshold exceeds both COPPA and most GDPR member state minimums, providing a more protective baseline but creating heightened compliance obligations if minors do access the service in practice. The FTC and EU DPAs actively enforce children's privacy requirements. GOVERNANCE EXPOSURE: Medium. The absence of described age verification mechanisms means the children's privacy protection is largely self-reported rather than technically enforced. For a location-tracking service, collection of minors' precise GPS data would carry significant regulatory risk under both COPPA and GDPR Article 8. The reactive deletion commitment ('if we learn') rather than proactive prevention is a gap frequently cited in FTC enforcement actions. JURISDICTION FLAGS: US (COPPA for under-13, FTC enforcement), EU member states (GDPR Article 8, varying age of consent), California (CCPA treats minors under 16 as requiring opt-in for data sale). The 18+ threshold means that in some GDPR jurisdictions, users aged 16-17 who would otherwise have capacity under local law are excluded from the service. CONTRACT AND VENDOR IMPLICATIONS: Age verification mechanisms, if implemented, may involve third-party identity verification vendors whose contracts should be reviewed for data minimization and children's data handling compliance. COMPLIANCE CONSIDERATIONS: Assess whether current account registration flow includes age verification, document procedures for handling discovered under-18 accounts including deletion timelines, confirm COPPA compliance program is in place including parental consent mechanisms as a safeguard, and review whether marketing and advertising channels could reach minors.
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The policy sets the age threshold at 18 rather than the COPPA standard of 13, which is a more protective approach for minors, but the enforcement mechanism relies on Lime discovering the collection rather than proactive age verification.
Lime's stated policy restricts service use to users 18 and older and commits to deleting data collected from users under 18, though the policy does not describe what technical or procedural measures are used to verify user age at account creation.
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