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The agreement requires users to be at least 13 years of age and requires that minors between age 13 and the age of majority in their state have a parent or guardian agree to the terms on their behalf.
This analysis describes what UnitedHealthcare'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 a minimum age of 13 and a parental consent requirement for minor users, engaging COPPA's applicability threshold and state-specific age of majority requirements. The agreement does not describe a mechanism for verifying parental consent.
Interpretive note: The agreement relies on user self-representation for age and parental consent without describing a verification mechanism; COPPA compliance depends on whether the platform is directed to children or whether the company has actual knowledge of under-13 users.
Under this clause, users must be at least 13 years old to use the Online Services, and minors below the age of majority who are not emancipated require parental or guardian agreement to the terms. The agreement does not describe a verification mechanism for confirming parental consent.
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"You represent and warrant that you are at least 13 years of age, and that, if you are between 13 and the age of majority in your state and otherwise not emancipated, a parent and/or guardian agrees to these Terms on your behalf.Excerpt from UnitedHealthcare's Terms of Use
(1) REGULATORY LANDSCAPE: The 13-year minimum age threshold aligns with the Children's Online Privacy Protection Act (COPPA), which imposes restrictions on online services directed to children under 13. The FTC enforces COPPA. The agreement's reliance on user representation rather than active age verification may not satisfy COPPA's verifiable parental consent requirements if the service is deemed directed to children or if the company has actual knowledge of under-13 users. (2) GOVERNANCE EXPOSURE: Medium. The absence of a described verification mechanism for parental consent for users aged 13 to the age of majority creates a compliance gap if minors access the platform without parental agreement to the terms. Healthcare platforms may have heightened sensitivity given the nature of plan information accessible through the Online Services. (3) JURISDICTION FLAGS: Several states have enacted or proposed child privacy protections beyond COPPA's federal baseline, including California's Age-Appropriate Design Code, which may impose additional obligations on platforms accessible by minors. (4) CONTRACT AND VENDOR IMPLICATIONS: Employer plan administrators whose plan members include minor dependents should assess whether this provision adequately governs minor access to plan information and whether additional consent mechanisms are required under applicable state law. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the self-representation mechanism for age and parental consent is consistent with COPPA requirements, assess state-specific child privacy laws applicable to the platform, and consider whether additional controls are needed for minor dependent access to health plan information.
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This provision establishes a minimum age of 13 and a parental consent requirement for minor users, engaging COPPA's applicability threshold and state-specific age of majority requirements. The agreement does not describe a mechanism for verifying parental consent.
Under this clause, users must be at least 13 years old to use the Online Services, and minors below the age of majority who are not emancipated require parental or guardian agreement to the terms. The agreement does not describe a verification mechanism for confirming parental consent.
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