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The policy establishes a Teen Account feature for users aged 13 to 17, where the parent or guardian Account Holder provides identifying information on behalf of the teen, and states that data collection is limited to what is required to use the account.
This analysis describes what Venmo'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 creates a distinct data governance structure for minor users aged 13 to 17, assigning control rights to the Account Holder (parent or guardian) while establishing that teen transaction data is shared with the Account Holder, The Bancorp Bank N.A., and Mastercard, among others. The provision engages both COPPA-adjacent frameworks for teens aged 13 to 17 and state children's privacy laws in jurisdictions that extend protections to this age group.
Interpretive note: The policy's statement that data collection is limited to what is required for the Teen Account does not specify how that limitation is operationalized or audited, and the applicability of California AADC obligations to this feature depends on regulatory interpretation.
Under this clause, Account Holders have the right to review, restrict, and request deletion of Teen Users' personal information, and the policy states that Teen User transaction data is disclosed to the Account Holder, The Bancorp Bank N.A., Mastercard, and merchants. Teen Users may review their own data and submit correction or deletion requests through the browser-based account privacy link.
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"We may offer an account holder ('Account Holder') the opportunity to create a Venmo Teen Account for use by an authorized individual between the ages of 13 and 17 years old at account creation ('Teen User'). We will not collect more information about you than what is required to use the Teen Account. What data do we collect? Identifiers: An Account Holder provides your name, birthday, address, and phone number. You will create a username/password for online account access. You will also provide your email address when you sign up for access to the app.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages COPPA, which the FTC enforces for users under 13, and state children's privacy laws in California (Age-Appropriate Design Code), Texas, and other states that extend protections to users aged 13 to 17. The disclosure to The Bancorp Bank N.A. and Mastercard engages GLBA and payment network data governance requirements. 2) GOVERNANCE EXPOSURE: Medium. The policy states data collection is limited to what is required for the Teen Account, but the disclosure to merchants, third-party digital wallets, and public-facing settings controlled by the Account Holder creates a layered privacy exposure for minor users that compliance teams may want to evaluate under applicable state minor privacy statutes. 3) JURISDICTION FLAGS: California's Age-Appropriate Design Code (AADC) creates heightened obligations for services directed at or likely to be accessed by minors, including data minimization, default privacy settings, and prohibition on profiling minors for advertising. The policy's disclosure that teen transaction data may be seen by friends and the public depending on Account Holder settings may engage AADC requirements. 4) CONTRACT AND VENDOR IMPLICATIONS: Disclosure to The Bancorp Bank N.A. and Mastercard for debit card services means Teen User data is subject to those entities' data governance frameworks in addition to Venmo's. The policy does not specify whether those downstream recipients are restricted from using Teen User data for non-transactional purposes. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the Teen Account feature satisfies California AADC data minimization and default privacy requirements, evaluate whether merchant disclosure of teen transaction data is consistent with applicable minor privacy protections, and confirm that Account Holder consent mechanisms satisfy any applicable state parental consent requirements for users aged 13 to 17.
This provision creates a distinct data governance structure for minor users aged 13 to 17, assigning control rights to the Account Holder (parent or guardian) while establishing that teen transaction data is shared with the Account Holder, The Bancorp Bank N.A., and Mastercard, among others. The provision engages both COPPA-adjacent frameworks for teens aged 13 to 17 and state children's …
Under this clause, Account Holders have the right to review, restrict, and request deletion of Teen Users' personal information, and the policy states that Teen User transaction data is disclosed to the Account Holder, The Bancorp Bank N.A., Mastercard, and merchants. Teen Users may review their own data and submit correction or deletion requests through the browser-based account privacy link.
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