The agreement prohibits users under 13 from accessing the Services and requires users between 13 and 18 to have parental or guardian consent. Luma states it does not knowingly collect personal information from children under 13 and will delete such information if discovered.
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
This provision establishes age-based access controls and a COPPA compliance commitment. The mechanism for enforcement relies on user self-representation at account creation rather than independent age verification, which is typical but creates a gap between stated policy and practical enforcement.
Under this clause, users under 13 are not authorized to use the Services, and users between 13 and 18 must have parental consent. The agreement states that personal information collected from users under 13 will be deleted upon discovery, and the document provides support@lumalabs.ai as a contact for reporting such concerns.
How other platforms handle this
Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...
For individuals in the United States, please also refer to our Notice For Individuals Residing In Certain US States below and the Consumer Health Data Policy.
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"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. COPPA NOTICE: Luma does 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
(1) REGULATORY LANDSCAPE: This provision directly engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The adequacy of self-representation as an age verification mechanism may require evaluation under FTC COPPA guidance and the FTC's recent enforcement posture on children's data. State-level children's privacy laws (including California's Age-Appropriate Design Code) may impose additional obligations. (2) GOVERNANCE EXPOSURE: Medium. COPPA compliance based on user self-representation is standard practice but has been subject to FTC scrutiny where platforms have constructive knowledge of minor users. Luma's platform involves creative AI generation that may attract younger users, which may heighten regulatory attention. (3) JURISDICTION FLAGS: California's Age-Appropriate Design Code (AADC) may impose design and data protection obligations for services likely to be accessed by minors, even without actual knowledge. UK Children's Code (AADC equivalent) creates similar obligations for UK operations. FTC COPPA enforcement is the primary federal mechanism in the US. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers deploying Luma in educational or youth-facing contexts should confirm that the Services are appropriate for their user base and that COPPA compliance obligations are addressed in their own agreements. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the self-representation mechanism is sufficient for COPPA compliance given Luma's user base characteristics, and whether any design features of the platform may attract users under 13. The reporting mechanism at support@lumalabs.ai should be operationally functional and response timelines documented.
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This provision establishes age-based access controls and a COPPA compliance commitment. The mechanism for enforcement relies on user self-representation at account creation rather than independent age verification, which is typical but creates a gap between stated policy and practical enforcement.
Under this clause, users under 13 are not authorized to use the Services, and users between 13 and 18 must have parental consent. The agreement states that personal information collected from users under 13 will be deleted upon discovery, and the document provides support@lumalabs.ai as a contact for reporting such concerns.
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