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For Runway's Characters and Game Worlds products, the policy prohibits characters based on the face or voice of individuals under 18, characters or games designed to engage minors, and characters or games intended to provide professional advisory content including medical, legal, financial, or therapeutic guidance.
This analysis describes what Runway'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
These product-specific prohibitions engage COPPA's restrictions on content and data collection directed at children under 13, and extend further to cover all minors under 18 in the context of likeness use; the prohibition on simulated professional advisory content may also engage sector-specific regulations in healthcare, legal, and financial services.
Interpretive note: The prohibition on content 'intended to engage users under the age of 18' does not define the threshold for intent determination, creating interpretive uncertainty for products that may be used by mixed-age audiences.
Under these product-specific provisions, users of Runway's Characters and Game Worlds tools are prohibited from creating characters or experiences targeting minors or simulating professional advisory roles; these restrictions apply in addition to the general usage policy prohibitions.
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"Characters based on the face or voice of a person under the age of 18. Characters or games that are intended to engage users under the age of 18, including narrative elements or visual styles intended for children Characters or games that are intended to provide medical, legal, or financial advice or mimic professional therapeutic or counseling interventions.Excerpt from Runway's Content Policy
(1) REGULATORY LANDSCAPE: The prohibition on characters targeting users under 18 engages COPPA (Children's Online Privacy Protection Act) for users under 13, administered by the FTC; state-level children's online safety laws (including California's Age-Appropriate Design Code) may impose broader obligations for content directed at minors up to 18. The prohibition on simulated medical, legal, financial, or therapeutic advisory content engages FTC guidance on AI-generated professional advice, as well as sector-specific regulations from the SEC (financial advice), state bar associations (legal advice), and HHS (medical advice). (2) GOVERNANCE EXPOSURE: Medium to High. The prohibition on therapeutic or counseling mimicry is particularly significant given the FTC's and state regulators' increased scrutiny of AI mental health tools; deploying Runway's Characters product for any wellness, counseling, or advisory application could trigger regulatory review. (3) JURISDICTION FLAGS: California's Age-Appropriate Design Code (AB 2273) and similar statutes in the UK (Children's Code under the UK GDPR) impose design and data protection requirements for services likely to be accessed by minors; enterprises deploying Characters or Game Worlds products should assess applicability in these jurisdictions. Financial advisory content restrictions may engage SEC and FINRA oversight in the U.S. and MiFID II in the EU. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprises deploying Characters or Game Worlds in consumer-facing applications should assess whether their target audience includes minors and whether any advisory functionality is contemplated, as either could trigger these prohibitions and associated account suspension risk. Platform developers integrating Runway's Characters API should document their audience targeting and content restrictions as part of vendor due diligence. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether existing age verification or audience targeting controls satisfy the policy's prohibition on content directed at under-18 users, particularly in light of California and UK children's code requirements. Organizations considering therapeutic or advisory AI applications built on Runway should obtain legal review of applicable professional licensing and consumer protection obligations before deployment.
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These product-specific prohibitions engage COPPA's restrictions on content and data collection directed at children under 13, and extend further to cover all minors under 18 in the context of likeness use; the prohibition on simulated professional advisory content may also engage sector-specific regulations in healthcare, legal, and financial services.
Under these product-specific provisions, users of Runway's Characters and Game Worlds tools are prohibited from creating characters or experiences targeting minors or simulating professional advisory roles; these restrictions apply in addition to the general usage policy prohibitions.
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