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
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 request that your data be transferred to a third party (data portability)
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"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.
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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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