Snapchat is not intended for children under 13, and the company states it deletes data if it discovers it has been collected from under-13 users; teenagers aged 13-17 have some additional protections but still use the full service.
This analysis describes what Snapchat'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
Given Snapchat's widespread use among teenagers, the adequacy of age verification and the specific nature of 'certain restrictions' for users aged 13-17 are material to assessing whether minors' data is adequately protected under COPPA and state children's privacy laws.
Interpretive note: The specific restrictions applied to teen accounts (ages 13-17) are referenced but not fully enumerated in this provision, creating interpretive uncertainty about the scope of protections actually in place.
Snapchat's privacy policy now includes expanded language describing how the platform collects, processes, and shares user data. The updated policy discloses additional practices and operational procedures governing user information. Review of the specific added sentences is necessary to determine whether new data collection, retention, or sharing practices are described, or whether existing practices receive clarified disclosure.
View change record →Teens aged 13-17 are subject to some additional privacy protections, but the policy does not fully enumerate what those restrictions are in this provision, meaning parents and guardians may not have a complete picture of how their children's data is handled.
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"Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete the information as soon as possible. Teens between 13 and 17 may use Snapchat subject to certain restrictions designed to provide additional protections.— Excerpt from Snapchat's Snapchat Privacy Policy
(1) REGULATORY LANDSCAPE: COPPA requires verifiable parental consent before collecting personal data from children under 13 in the US, enforced by the FTC. The FTC has brought enforcement actions against social platforms for COPPA violations including inadequate age verification and unauthorized collection of children's data. Several states have enacted or are considering children's online privacy laws (e.g., California's AADC, the federal Kids Online Safety Act) that extend protections to users under 16 or 18. GDPR Article 8 sets a baseline age of consent for information society services at 16, with member state flexibility to lower to 13. (2) GOVERNANCE EXPOSURE: High. Snapchat's demographic is well-documented to include a substantial proportion of users under 18, and regulators globally have increased scrutiny of social platforms' handling of minors' data. The policy's description of 'certain restrictions' for teens without specificity creates a disclosure adequacy concern. (3) JURISDICTION FLAGS: California's Age-Appropriate Design Code (AADC) imposes design and data minimization requirements for services likely to be accessed by users under 18. UK's Age-Appropriate Design Code (Children's Code) enforced by the ICO creates similar obligations. EU member states have varying age thresholds for digital consent. Illinois, Texas, and other states with biometric privacy laws may apply to camera-based features used by minors. (4) CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising partners receiving data about users who are or may be minors face significant regulatory exposure; advertising data flows involving minors require careful contractual and operational controls. (5) COMPLIANCE CONSIDERATIONS: Legal teams should audit Snap's age-gating mechanisms and assess whether the 'certain restrictions' applied to teen accounts are operationally implemented, documented, and compliant with COPPA, GDPR Article 8, and applicable state children's privacy laws. Parental notification and consent processes should be reviewed for adequacy.
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Given Snapchat's widespread use among teenagers, the adequacy of age verification and the specific nature of 'certain restrictions' for users aged 13-17 are material to assessing whether minors' data is adequately protected under COPPA and state children's privacy laws.
Teens aged 13-17 are subject to some additional privacy protections, but the policy does not fully enumerate what those restrictions are in this provision, meaning parents and guardians may not have a complete picture of how their children's data is handled.
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