Users who indicate they are children are placed in a 'Cabined Account' with restricted features and limited data collection until a parent provides consent for a full account, verified through Epic's subsidiary Kids Web Services (KWS).
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The provision operationalizes age-based access controls by automatically limiting feature availability for child accounts, establishing a baseline privacy posture that requires affirmative parental authorization to modify. This mechanism ensures that certain features—specifically voice communication and paid transactions—do not activate for child users without explicit guardian consent.
Children in Cabined Accounts have their data limited to essential identifiers including email hash, IP address, and device IDs, but once a parent grants consent through KWS, Epic's full data collection practices — including advertising data sharing — apply to the child's account, which parents may not fully appreciate when clicking through the consent flow.
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"When a user indicates they are a child, they are placed in a "Cabined Account" until they are no longer a child as defined above or until their parent/guardian provides additional privacy permissions and enables parental controls. Cabined Accounts can play Epic's games (e.g., Fortnite, Rocket League, or Fall Guys), but features like voice chat and real money purchases are disabled.— Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY FRAMEWORK: This provision directly implicates COPPA (15 U.S.C. §6501 et seq., 16 C.F.R. Part 312), which requires verifiable parental consent before collecting personal information from children under 13, enforced by the FTC with civil penalties up to $51,744 per violation; GDPR Article 8 (age of digital consent, minimum 13, up to 16 depending on member state), enforced by EU DPAs; UK GDPR and the Age Appropriate Design Code (Children's Code) enforced by the ICO; and CCPA/CPRA which extends special protections to minors under 16 (opt-in consent for sale/sharing of data for users 13–15).
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The provision operationalizes age-based access controls by automatically limiting feature availability for child accounts, establishing a baseline privacy posture that requires affirmative parental authorization to modify. This mechanism ensures that certain features—specifically voice communication and paid transactions—do not activate for child users without explicit guardian consent.
Children in Cabined Accounts have their data limited to essential identifiers including email hash, IP address, and device IDs, but once a parent grants consent through KWS, Epic's full data collection practices — including advertising data sharing — apply to the child's account, which parents may not fully appreciate when clicking through the consent flow.
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