OpenAI states that its services are not for children under 13 and that it does not intentionally collect data from them; if it discovers a child's data has been collected, it states it will delete it.
This analysis describes what OpenAI'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 the age threshold for service eligibility and invokes COPPA compliance obligations; the 'knowingly' qualifier means enforcement depends on OpenAI's ability to detect underage users, which relies primarily on age declared at registration.
The updated policy no longer explicitly states that OpenAI receives information from advertisers and other data partners for ad measurement and improvement, nor does it mention that users can control…
The updated policy now explicitly authorizes OpenAI to promote products and services to users through direct marketing on third-party properties and to share limited information with select marketing…
The updated policy removes explicit language describing how OpenAI shares personal data with marketing partners through cookies and similar technologies. The policy previously stated that 'some of th…
The policy states that users under 13 are not permitted to use OpenAI services and that data collected from such users will be deleted if discovered; parents who believe their child has created an account can request deletion through privacy.openai.com.
How other platforms handle this
Depending on where you live, you may have certain rights with respect to your personal information. These rights may include: The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected i...
Replit does not knowingly collect personal information from children under 13. Users between the ages of 13 and 18 may use the platform with parental or guardian consent. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will delete...
If you are located in the EEA, UK, or Switzerland, you have certain rights with respect to your personal information, including the right to access your personal data, to correct or delete your personal data, to restrict processing of your personal data, to data portability, and to object to process...
Monitoring
OpenAI has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.
"Our services are not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.— Excerpt from OpenAI's OpenAI Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which prohibits operators from collecting personal information from children under 13 without verifiable parental consent. The FTC has taken enforcement action against technology platforms for inadequate age verification and insufficient parental consent mechanisms. The 'knowingly' standard in COPPA means that platforms are not strictly liable for all underage data collection but must have reasonable mechanisms to detect and respond to known violations. GOVERNANCE EXPOSURE: Medium. The policy relies on user-declared age without describing any technical age verification mechanism, which is a common industry approach but one that the FTC has scrutinized in enforcement actions. If OpenAI becomes aware that a significant number of underage users are accessing its services, the adequacy of its current controls may be assessed under COPPA. JURISDICTION FLAGS: COPPA applies federally across all US jurisdictions. Some states including California have enacted additional children's privacy laws (California Age-Appropriate Design Code, also known as AB 2273) that impose broader obligations for services likely to be accessed by minors under 18. The applicability of the California AADC to OpenAI's consumer products may warrant separate legal assessment. CONTRACT AND VENDOR IMPLICATIONS: Educational institutions and other organizations that may facilitate student access to OpenAI products should assess whether FERPA obligations or the Children's Internet Protection Act impose additional requirements beyond COPPA. Vendor agreements with educational organizations should confirm which product tier applies and whether FERPA-compliant data processing terms are available. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that age verification or attestation mechanisms at account creation are documented and that the deletion process for identified underage user data is operationally tested. The California AADC's applicability to OpenAI's services should be assessed given the product's broad consumer accessibility.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.
Professional Governance Intelligence
Need to monitor specific governance provisions?
Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision establishes the age threshold for service eligibility and invokes COPPA compliance obligations; the 'knowingly' qualifier means enforcement depends on OpenAI's ability to detect underage users, which relies primarily on age declared at registration.
The policy states that users under 13 are not permitted to use OpenAI services and that data collected from such users will be deleted if discovered; parents who believe their child has created an account can request deletion through privacy.openai.com.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.