OpenAI's services are not intended for children under 13, and parents can request deletion of a child's data through OpenAI's privacy portal if they believe their child has submitted personal information.
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 minimum age as 13, which aligns with COPPA's threshold; however, it does not describe age verification mechanisms, which may affect practical enforcement of this restriction.
The policy states that services are not directed to children under 13 and provides a mechanism for parents to request deletion of a child's data. The policy does not describe how OpenAI verifies user age at account creation.
How other platforms handle this
By using Pinterest, you state that: you are at least 13 years old and you are old enough to legally consent to use Pinterest in your country. If we learn that we've collected the personal information of a child under the age of 13 without parental consent, we will take steps to delete the informatio...
The Waze App is not intended for use by children. We do not knowingly collect personal information from children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be higher, such as 16 in certain EU member states). If we become aware that we have collected...
YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
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"Our Services are not directed to children under the age of 13. If you believe that a child under 13 has provided Personal Data to OpenAI, you can request deletion of that information through our privacy portal at privacy.openai.com.— Excerpt from OpenAI's Privacy Policy (ROW)
REGULATORY LANDSCAPE: COPPA applies to online services directed to children under 13 or with actual knowledge they are collecting personal data from children under 13, enforced by the FTC. The FTC has brought enforcement actions against services that inadequately screen for child users. Some U.S. states, including California under the Age-Appropriate Design Code, impose additional obligations for services likely to be accessed by minors up to age 17. GOVERNANCE EXPOSURE: Medium. The policy's statement that services are 'not directed to' children under 13 is a standard COPPA formulation, but the absence of described age verification mechanisms means that actual knowledge claims and age-screening adequacy may be scrutinized if children are found to be using the services. JURISDICTION FLAGS: California's Age-Appropriate Design Code (if in effect) and COPPA create overlapping obligations. UK Age Appropriate Design Code (Children's Code) applies for EEA/UK users. Organizations deploying OpenAI in educational or family-oriented contexts face heightened exposure. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying OpenAI services in contexts where minors may be users should obtain specific contractual representations regarding COPPA compliance and assess whether OpenAI qualifies as an operator under COPPA in their deployment context. COMPLIANCE CONSIDERATIONS: Organizations should assess whether their use case creates actual knowledge of child users and whether additional safeguards beyond OpenAI's stated policy are required. Schools and educational platforms face COPPA and FERPA considerations that require separate evaluation.
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This provision establishes the minimum age as 13, which aligns with COPPA's threshold; however, it does not describe age verification mechanisms, which may affect practical enforcement of this restriction.
The policy states that services are not directed to children under 13 and provides a mechanism for parents to request deletion of a child's data. The policy does not describe how OpenAI verifies user age at account creation.
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