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The policy prohibits use of the service by children under 13 and states that personal data from under-13 users will be deleted upon notification. Users aged 13-17 require parental or guardian permission, and parents or guardians may link accounts with teen users to manage settings and receive safety alerts.
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 gating structure for OpenAI's consumer services, distinguishing between under-13 (excluded) and 13-17 (permitted with parental permission). The policy also discloses a teen account linking mechanism that allows parents or guardians to manage settings and receive alerts for serious safety concerns, which is a distinct operational feature beyond standard COPPA compliance.
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 →Under these terms, users under 13 are excluded from the service and their data will be deleted upon notification. Teen users between 13 and 17 may use the service with parental permission, and the policy authorizes parents or guardians who link accounts to access certain settings and receive safety-related alerts.
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"Our Services are not directed to, or intended for, children under 13. We do not knowingly collect Personal Data from children under 13. If you have reason to believe that a child under 13 has provided Personal Data to OpenAI through the Services, please email us at privacy@openai.com. We will investigate any notification and, if appropriate, delete the Personal Data from our systems. Users under 18 must have permission from their parent or guardian to use our Services.Excerpt from OpenAI's Privacy Policy
1) REGULATORY LANDSCAPE: The under-13 prohibition and deletion commitment directly engage COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal data from children under 13. The 13-17 parental permission requirement and account linking feature engage state minor privacy laws, including California's Age-Appropriate Design Code (AB 2273), though that law's status has been subject to litigation. The FTC has taken active enforcement action against platforms that fail to implement adequate age verification for COPPA-covered populations. 2) GOVERNANCE EXPOSURE: Medium. The policy relies on a self-reported age gating model supplemented by age estimation for appropriate experiences, rather than verified parental consent for the 13-17 bracket. The account linking feature for teens introduces a parental data access mechanism that has operational implications for both the teen user's privacy and the parent's data access rights. 3) JURISDICTION FLAGS: California's Age-Appropriate Design Code creates heightened obligations for services used by minors. Illinois and other states with minor privacy protections may impose additional requirements. The separate EEA/UK policy addresses GDPR Article 8 requirements for processing children's data in those jurisdictions, which may set the age of digital consent differently. 4) CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying OpenAI services in educational or family-oriented contexts should assess whether the consumer-facing age gating provisions are consistent with COPPA, FERPA, and applicable state requirements for their specific use case. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the age verification mechanisms referenced in the policy (vendor-assisted identity and age verification disclosed elsewhere in the document) meet COPPA's verifiable parental consent standard. The teen account linking feature should be evaluated against applicable minor privacy frameworks for the operational jurisdictions.
This provision establishes the age gating structure for OpenAI's consumer services, distinguishing between under-13 (excluded) and 13-17 (permitted with parental permission). The policy also discloses a teen account linking mechanism that allows parents or guardians to manage settings and receive alerts for serious safety concerns, which is a distinct operational feature beyond standard COPPA compliance.
Under these terms, users under 13 are excluded from the service and their data will be deleted upon notification. Teen users between 13 and 17 may use the service with parental permission, and the policy authorizes parents or guardians who link accounts to access certain settings and receive safety-related alerts.
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