OpenAI's services are not intended for children under 13, and the company states it will delete any personal data it discovers was collected from a child under that age.
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 implements compliance requirements under the Children's Online Privacy Protection Act (COPPA) and similar child privacy regulations. It establishes OpenAI's operational stance regarding age-gated service access and creates a data deletion procedure for inadvertently collected information from children under 13.
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 →Parents should be aware that no technical age verification is described in the policy; if a child under 13 uses the service, their conversation data may be collected before any corrective deletion occurs.
How other platforms handle this
Without limiting the generality of the foregoing, any access to, or use of, the Service by anyone who is a minor (which is under the age of 18 in most jurisdictions) in any applicable jurisdiction (a "Minor") is strictly prohibited and in violation of these Terms, unless such access and/or use is su...
"Our services are not directed to children under the age of 13. If you are under 13, please do not use our services or provide us with any personal information. If we learn that we have collected personal information from a child under 13, we will delete it. If you believe a child under 13 has provided us with personal information, please contact us at privacy@openai.com.Excerpt from OpenAI's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly implicates COPPA (Children's Online Privacy Protection Act), enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision implements compliance requirements under the Children's Online Privacy Protection Act (COPPA) and similar child privacy regulations. It establishes OpenAI's operational stance regarding age-gated service access and creates a data deletion procedure for inadvertently collected information from children under 13.
Parents should be aware that no technical age verification is described in the policy; if a child under 13 uses the service, their conversation data may be collected before any corrective deletion occurs.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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