Even children in restricted Cabined Accounts have their IP address, device IDs, and gaming platform account IDs collected by Epic for operational and analytics purposes, though Epic states these identifiers are technically restricted from being used for other purposes.
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
Persistent identifiers collected from children, including IP addresses and device IDs, are sensitive data categories under COPPA and equivalent laws, and the sufficiency of the asserted technical controls determines whether this practice complies with those frameworks.
Interpretive note: Whether the analytics use of children's persistent identifiers qualifies as a permissible internal operations exception under COPPA's 2024 amended rule is a contested legal question that depends on FTC interpretation and enforcement posture.
Parents should be aware that even before granting any consent, their child's IP address, device ID, and gaming platform account ID are collected by Epic when a child creates a Cabined Account, and that these identifiers are used for analytics to improve the Epic Services in addition to strictly operational purposes.
How other platforms handle this
You and your organization's administrator can access several types of Service Data directly from Google Cloud, including your account information, billing contact information, payment and transaction information, as well as product and communication settings and configurations.
To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.
If you registered to use Notion's Services with such an email address, but you do not use the Services in connection with your organization...you may transfer your account to a different email address.
"persistent identifiers of the child like IP address, Epic account ID, gaming platform account IDs, device IDs, and similar data collected with website tracking technologies to provide and maintain the Epic Services (including analytics to improve them), authenticate users, protect the security and integrity of users and the Epic Services, comply with legal and regulatory requirements, facilitate personalization, and maintain user driven preferences (e.g., game advancement and avatar choice). We use technical and organizational means designed to ensure that those persistent identifiers of Cabined Accounts are not used for other purposes.Excerpt from Unreal Engine's Epic Games Privacy Policy
REGULATORY LANDSCAPE: This provision directly implicates COPPA (16 CFR Part 312), including the FTC's 2024 amended rule, which expanded the definition of personal information to include persistent identifiers and tightened restrictions on their use without …
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Persistent identifiers collected from children, including IP addresses and device IDs, are sensitive data categories under COPPA and equivalent laws, and the sufficiency of the asserted technical controls determines whether this practice complies with those frameworks.
Parents should be aware that even before granting any consent, their child's IP address, device ID, and gaming platform account ID are collected by Epic when a child creates a Cabined Account, and that these identifiers are used for analytics to improve the Epic Services in addition to strictly operational purposes.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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