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The policy states that the Services are not directed to children under 13 in the US and that Replit will take reasonable steps to obtain parental consent or delete personal information of users found to be underage. Student profiles created in Teams for Education are separately stated to be non-public.
This analysis describes what Replit'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 Replit's stated approach to COPPA compliance for the general platform, relying on user self-representation of age eligibility rather than proactive age verification. The separately stated protection for Teams for Education student profiles addresses an education-specific use case with different default visibility settings.
Interpretive note: The adequacy of self-representation age verification under COPPA enforcement standards is subject to FTC interpretation and may vary depending on the specific deployment context and user demographics of a given Replit application.
Under this clause, users are required to represent at account creation that they meet applicable age requirements; if Replit discovers an underage user, it states it will seek parental consent or delete the account. Student accounts created through Teams for Education are stated to be non-publicly visible and non-searchable.
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"Our Services are directed to a general audience and are not directed to children under the age of 13. By agreeing to our Privacy Policy and Terms of Service, you represent that you are allowed to use our Services according to your country's applicable age limits. If we learn that a child is under the age of 13 in the United States, or is under the applicable age requirement in another jurisdiction, we will take reasonable steps to obtain parental consent or delete the user's personal information from our files as soon as is practicable. Please contact us at privacy@replit.com if you believe that a user has provided us with representations in violation of this Privacy Policy.Excerpt from Replit's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The policy's reliance on self-representation rather than affirmative age verification may require evaluation against FTC COPPA enforcement standards. GDPR Article 8 imposes parental consent requirements for children's data processing in EEA member states, with age thresholds varying by country from 13 to 16. The UK GDPR and the UK Children's Code impose additional age-appropriate design requirements. 2) GOVERNANCE EXPOSURE: Medium. Replit's general platform is described as not directed to children under 13, but the platform is widely used in educational contexts. The reliance on self-representation for age verification rather than technical age gating creates COPPA exposure if underage users access the general platform. The Teams for Education carve-out addresses the structured educational context but does not eliminate exposure from informal educational use on the general platform. 3) JURISDICTION FLAGS: United States COPPA requirements are directly applicable. EEA member states have varying parental consent age thresholds under GDPR Article 8. The UK Children's Code imposes age-appropriate design obligations that extend beyond consent to include default privacy settings, data minimization, and profiling restrictions for users likely to be children. Illinois and California have state-level minor privacy provisions that may also apply. 4) CONTRACT AND VENDOR IMPLICATIONS: Educational institutions procuring Replit should confirm that their use is structured through Teams for Education to access the non-public student profile environment described in the policy. Institutional agreements should specify age verification and parental consent procedures and confirm that FERPA compliance is addressed in the DPA or a separate agreement. 5) COMPLIANCE CONSIDERATIONS: Organizations using Replit in educational settings should obtain and review the Teams for Education agreement and any associated DPA provisions addressing FERPA and COPPA. Legal teams should assess whether Replit's self-representation age verification model satisfies the FTC's COPPA requirements for their specific deployment context. UK-based users and organizations should assess compliance with the UK Age Appropriate Design Code.
This provision establishes Replit's stated approach to COPPA compliance for the general platform, relying on user self-representation of age eligibility rather than proactive age verification. The separately stated protection for Teams for Education student profiles addresses an education-specific use case with different default visibility settings.
Under this clause, users are required to represent at account creation that they meet applicable age requirements; if Replit discovers an underage user, it states it will seek parental consent or delete the account. Student accounts created through Teams for Education are stated to be non-publicly visible and non-searchable.
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