The policy states that Epic uses Kids Web Services Ltd, a subsidiary, to verify parent/guardian email addresses and user ages for Cabined Account consent purposes. Once verified, the KWS system recognizes the verified email across all services using KWS technology, eliminating repeat verification.
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 establishes that parental consent and age verification are processed by a subsidiary (Kids Web Services Ltd) and that verified credentials are shared across all KWS-powered services. Compliance teams should evaluate whether this cross-service recognition mechanism is disclosed with sufficient specificity under COPPA and GDPR to constitute adequate informed consent, and whether the processing of parental email data by a subsidiary constitutes a sub-processor arrangement with appropriate contractual safeguards.
Interpretive note: The policy does not fully specify the scope of third-party services covered by the cross-service KWS verification recognition, creating ambiguity about the extent of parental consent coverage across non-Epic platforms.
Under this provision, a parent or guardian who verifies their email through KWS will have that verification recognized across all games and services using KWS technology operated by Epic or third-party partners. The cross-service scope of this recognition may extend beyond Epic's own services to third-party platforms using KWS.
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"We use Kids Web Services ("KWS"), a service offered by our subsidiary Kids Web Services Ltd, for parent/guardian and user age verification purposes. Once an email address is verified, KWS will recognize it across other games or services powered by KWS technology, so there will be no need to verify it again. When a parent/guardian provides consent for a non-Cabined Account for their child, parental controls are enabled automatically.Excerpt from Unreal Engine's Epic Games Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages COPPA's verifiable parental consent requirements (16 CFR 312.5) and GDPR Article 8's conditions for processing children's data.
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This provision establishes that parental consent and age verification are processed by a subsidiary (Kids Web Services Ltd) and that verified credentials are shared across all KWS-powered services. Compliance teams should evaluate whether this cross-service recognition mechanism is disclosed with sufficient specificity under COPPA and GDPR to constitute adequate informed consent, and whether the processing of parental email data by …
Under this provision, a parent or guardian who verifies their email through KWS will have that verification recognized across all games and services using KWS technology operated by Epic or third-party partners. The cross-service scope of this recognition may extend beyond Epic's own services to third-party platforms using KWS.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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