Luma AI · Luma AI Terms of Service · View original document ↗

COPPA Age Restriction and Under-13 Data Deletion

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Children under 13 are not allowed to use Luma. If a child under 13 has created an account, their personal information will be deleted, and you can report this to support@lumalabs.ai.

This analysis describes what Luma AI'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes COPPA compliance obligations and provides a reporting mechanism for parents who believe their child's data has been collected without authorization.

Consumer impact (what this means for users)

Parents and guardians should be aware that children under 13 are prohibited from using Luma, and any personal information collected from a child under 13 will be deleted upon discovery. Users aged 13 to 17 require parental or guardian consent to use the service.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    If you believe a child under 13 has created a Luma account, email support@lumalabs.ai to report the situation and request deletion of the child's personal information.

How other platforms handle this

Wealthfront Medium

Client Deletion Requests. In connection with separate regulatory recordkeeping obligations imposed on Wealthfront, we generally must maintain and cannot delete Personal Information associated with our Clients.

ElevenLabs Medium

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.

Replit Medium

Replit is not directed to children under the age of 13. If you are under 13 years of age, you are not permitted to use the Services. If we learn that we have collected Personal Information from a child under age 13, we will take steps to delete such information from our files as soon as possible.

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▸ View Original Clause Language DOCUMENT RECORD
"
You represent and warrant that: (a) you have not previously been suspended or removed from the Services; (b) your use of the Services complies with all Laws; and (c) you are at least 18 years old (or, if between 13 and 18, that you have your parent's or legal guardian's consent to be bound by this Agreement). Users under 13 are not authorized to use the Services. Luma will not knowingly collect personal information from children under 13. If Luma discovers that a user under 13 has provided personal information, it will promptly delete that information; contact support@lumalabs.ai if you believe this has occurred.

— Excerpt from Luma AI's Luma AI Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The provision's assertion that Luma will not knowingly collect personal information from under-13 users is a standard COPPA compliance statement. However, the FTC has consistently held that platform operators bear affirmative obligations to implement age verification mechanisms, not merely to disclaim liability for underage use. (2) GOVERNANCE EXPOSURE: Medium. The provision's reliance on user self-representation rather than active age verification creates regulatory exposure under COPPA if under-13 users access the platform. The FTC has taken enforcement action against platforms that relied solely on user-represented age without adequate technical safeguards, particularly where the platform's content or context might reasonably attract minors. (3) JURISDICTION FLAGS: COPPA applies federally in the United States. The EU's GDPR imposes analogous protections for children under 16 in most EU member states (with member state discretion to lower the threshold to 13). The UK Children's Code (Age Appropriate Design Code) may impose additional obligations for services likely to be accessed by under-18 users in the UK. Given Luma's generative AI capabilities, regulatory scrutiny of its age verification practices is foreseeable. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying Luma in educational or youth-facing contexts should independently assess whether adequate technical controls exist to prevent under-13 access. Parental consent mechanisms should be verified as meeting the FTC's verifiable parental consent standard under COPPA rather than relying on the user representation in this agreement. (5) COMPLIANCE CONSIDERATIONS: Luma's compliance team should evaluate whether its account creation flow includes adequate technical age verification measures beyond self-reported age. Organizations integrating Luma APIs into services that may attract minors should conduct COPPA impact assessments. Any reports received at support@lumalabs.ai regarding under-13 users should trigger a documented data deletion process consistent with COPPA's requirements.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and has jurisdiction over the collection of personal information from children under 13 without verifiable parental consent
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Luma AI Terms of Service
Entity
Luma AI
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 11, 2026
Record ID
CA-P-010499
Document ID
CA-D-00498
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
5362786653ea9970514f2dc6e0e31ab57e6cf1c79e8efe630a99873e8b72ec4e
Analysis generated
May 11, 2026 06:40 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Luma AI
Document: Luma AI Terms of Service
Record ID: CA-P-010499
Captured: 2026-05-11 06:40:34 UTC
SHA-256: 5362786653ea9970…
URL: https://conductatlas.com/platform/luma-ai/luma-ai-terms-of-service/coppa-age-restriction-and-under-13-data-deletion/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Luma AI's COPPA Age Restriction and Under-13 Data Deletion clause do?

This provision establishes COPPA compliance obligations and provides a reporting mechanism for parents who believe their child's data has been collected without authorization.

How does this clause affect you?

Parents and guardians should be aware that children under 13 are prohibited from using Luma, and any personal information collected from a child under 13 will be deleted upon discovery. Users aged 13 to 17 require parental or guardian consent to use the service.

Is ConductAtlas affiliated with Luma AI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Luma AI.