OpenAI's services are not meant for children under 13, and OpenAI says it will delete data from children under 13 if discovered, but the policy relies on self-reported age rather than technical verification.
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 reflects OpenAI's compliance framework under the Children's Online Privacy Protection Act (COPPA) and establishes the operational process by which the company addresses unauthorized collection of data from minors under 13. It creates a mechanism for parental notification and remediation of potential age-restricted access.
The updated policy explicitly discloses that OpenAI receives information from advertisers and other data partners for Free and Go users, and uses this data to personalize ads and measure ad effectiveness. The policy now states that Free and Go users can control what data OpenAI uses to personalize ads through advertising controls in account settings. This represents clarified disclosure of an existing practice rather than a new authorization.
View change record →The updated privacy policy now explicitly states that OpenAI receives information from advertisers and other data partners, which is used to personalize ads shown to Free and Go users and to measure the effectiveness of those ads. For example, the policy notes that OpenAI could receive information about purchases users make from advertisers. The policy now includes a dedicated section on ad personalization and measurement as a primary use of personal data for these user tiers. You can manage what data OpenAI uses for ad personalization by accessing the advertising controls in your account settings or by using the Data Controls option.
View change record →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 partners (who are not service providers) to support these efforts. The policy states that some marketing partners may receive information through cookies and similar technologies. The revised terms establish that these marketing practices are subject to user choices and controls, with additional information and opt-out options available. You can make choices about the use of your information for third-party product promotion purposes through controls referenced in the policy.
View change record →Children under 13 are technically prohibited from using OpenAI's services, but the lack of age verification means minors may use ChatGPT and have their personal data collected and potentially used for AI training before any corrective action is taken.
How other platforms handle this
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
Not be Discriminated Against by us for exercising your privacy rights.
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
"Our Services are not directed to children under 13. If you are a parent or guardian and believe that your child has provided personal information to OpenAI without your consent, please contact us at privacy@openai.com. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as quickly as possible.Excerpt from OpenAI's Privacy Policy
(1) REGULATORY FRAMEWORK: COPPA (Children's Online Privacy Protection Act), 15 U.S.C.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision reflects OpenAI's compliance framework under the Children's Online Privacy Protection Act (COPPA) and establishes the operational process by which the company addresses unauthorized collection of data from minors under 13. It creates a mechanism for parental notification and remediation of potential age-restricted access.
Children under 13 are technically prohibited from using OpenAI's services, but the lack of age verification means minors may use ChatGPT and have their personal data collected and potentially used for AI training before any corrective action is taken.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.