Beginning April 2026, the policy states that personal information associated with children's accounts inactive for 18 consecutive months will be deleted, as defined by the Children's Online Privacy Protection Rule.
This analysis describes what Unreal Engine'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 reflects the data retention obligations introduced by the FTC's 2024 amendments to the COPPA rule, which require operators to establish and maintain a retention schedule and delete children's personal information when it is no longer necessary for the purpose for which it was collected. The specific April 2026 implementation date and 18-month threshold are operationally significant for Epic's data infrastructure and for any downstream processors handling Cabined Account data.
Under this provision, personal information associated with children's accounts that have been inactive for 18 months will be deleted beginning April 2026, as defined by 16 CFR 312.2. Parents and guardians do not need to take action to trigger this deletion for inactive accounts.
How other platforms handle this
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
We retain your personal information for as long as necessary to provide our Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Even after you close your account, we may retain certain information as required by law or for our legitimate business purposes.
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"Starting in April 2026, if a child's account remains inactive for 18 months, personal information associated with the account will be deleted (as defined by Children's Online Privacy Protection Rule, 16 CFR 312.2).— Excerpt from Unreal Engine's Epic Games Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly references and implements the retention and deletion requirements of the Children's Online Privacy Protection Rule (16 CFR 312.2) as amended by the FTC's 2024 COPPA rule. The FTC is the primary enforcement authority. The provision's explicit April 2026 effective date indicates this is a newly implemented compliance measure aligned with the updated COPPA framework. 2) GOVERNANCE EXPOSURE: Medium. The provision demonstrates regulatory alignment with updated COPPA requirements. Operational exposure exists if the data deletion mechanism is not implemented on schedule or if the definition of activity under 16 CFR 312.2 is applied inconsistently across Epic's systems. 3) JURISDICTION FLAGS: United States, specifically federal COPPA enforcement. EU/EEA data minimization obligations under GDPR Article 5(1)(e) independently require storage limitation, and equivalent deletion obligations may apply under national youth privacy laws in EU member states regardless of the COPPA implementation timeline. 4) CONTRACT AND VENDOR IMPLICATIONS: Service providers, cloud storage operators, and gaming platform partners receiving Cabined Account data from Epic should review their own data retention and deletion obligations to ensure they can execute deletion requests on a compatible schedule with Epic's 18-month policy. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that data infrastructure across all Epic subsidiaries and third-party processors is configured to identify and execute deletion of children's account data after 18 months of inactivity as of April 2026. The definition of inactivity under 16 CFR 312.2 should be mapped to Epic's account activity tracking systems. Audit trails documenting deletion execution should be maintained for regulatory review.
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This provision reflects the data retention obligations introduced by the FTC's 2024 amendments to the COPPA rule, which require operators to establish and maintain a retention schedule and delete children's personal information when it is no longer necessary for the purpose for which it was collected. The specific April 2026 implementation date and 18-month threshold are operationally significant for Epic's …
Under this provision, personal information associated with children's accounts that have been inactive for 18 months will be deleted beginning April 2026, as defined by 16 CFR 312.2. Parents and guardians do not need to take action to trigger this deletion for inactive accounts.
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