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Snap prohibits use of the Services by persons under age 13, or the higher applicable minimum age in the user's jurisdiction, and states it will delete the account and data of any user it identifies as being below that age threshold.
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
The agreement establishes an age-gating requirement consistent with COPPA's minimum age threshold of 13, and commits to account and data deletion upon actual knowledge of underage use. The 'actual knowledge' standard rather than a verification-based standard is the operative trigger for this obligation.
Under this clause, users under age 13, or the applicable higher minimum age in their jurisdiction, are not permitted to use the Services, and the agreement states Snap will delete the account and associated data of any user identified as below that threshold upon obtaining actual knowledge.
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"Our Services are not directed to children under the age of 13, and you must confirm that you are 13 years or older to create an account and use the Services. If we have actual knowledge that you are under the age of 13 (or the minimum age at which a person may use the Services in your state, province, or country without parental consent, if greater), we will cease providing the Services to you and delete your account and your data.Excerpt from Snapchat's Terms of Service
REGULATORY LANDSCAPE: This provision directly engages COPPA, which prohibits online collection of personal information from children under 13 without verifiable parental consent, enforced by the FTC. The reference to jurisdiction-specific minimum ages engages state and international equivalents, including the UK Age Appropriate Design Code and similar frameworks. The FTC has active enforcement posture regarding COPPA compliance by major consumer platforms. GOVERNANCE EXPOSURE: High. The 'actual knowledge' standard for triggering the deletion obligation, rather than a proactive age verification mechanism, may be evaluated by the FTC against the standard of COPPA's requirements for platforms with services that are directed to children or that the platform has reason to believe are used by children. JURISDICTION FLAGS: COPPA applies in the United States with FTC enforcement. The UK Age Appropriate Design Code imposes additional design and data protection obligations for services likely to be accessed by minors, applicable to Snap Group Limited users under the separate agreement. California's Age-Appropriate Design Code Act creates additional obligations for California-based minor users. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying Snap Services in educational or youth-facing contexts should assess whether the 'actual knowledge' deletion standard provides adequate COPPA compliance coverage for their use case and whether additional parental consent mechanisms are required. COMPLIANCE CONSIDERATIONS: Compliance teams should assess the age verification and enforcement mechanisms Snap employs to establish actual knowledge of underage users, as the adequacy of those mechanisms is a core COPPA compliance question. The data deletion commitment upon identifying underage users should be evaluated against applicable data retention and deletion timelines required by COPPA and analogous state statutes.
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The agreement establishes an age-gating requirement consistent with COPPA's minimum age threshold of 13, and commits to account and data deletion upon actual knowledge of underage use. The 'actual knowledge' standard rather than a verification-based standard is the operative trigger for this obligation.
Under this clause, users under age 13, or the applicable higher minimum age in their jurisdiction, are not permitted to use the Services, and the agreement states Snap will delete the account and associated data of any user identified as below that threshold upon obtaining actual knowledge.
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