Walgreens states its digital services are not intended for children under 13 and will delete any personal data it learns was collected from a child under that age.
This analysis describes what Walgreens'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
COPPA imposes strict obligations on operators of websites directed to children, and the 'knowingly' standard creates operational questions about verification of age for platforms accessible to the general public.
Children under 13 are not intended to use Walgreens digital services, and any data collected from a child under 13 is stated to be deleted upon discovery, though no active age verification mechanism is described in this provision.
How other platforms handle this
Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected personal information from a child under the age of 13 without parental consent, we wil...
Our online services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible.
Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without parental consent, we will take steps to delete such information. In some juris...
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"Our websites and apps are not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will delete it.— Excerpt from Walgreens's Walgreens Privacy Policy
REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which prohibits collecting personal information from children under 13 without verifiable parental consent. The 'knowingly' standard in COPPA means operators must have mechanisms reasonably designed to detect and address child users. FTC enforcement of COPPA has included significant civil penalties against major platforms. GOVERNANCE EXPOSURE: Medium. The provision states a compliant position but does not describe the operational mechanisms used to identify or prevent data collection from users under 13. Pharmacy and health services accessible through Walgreens digital properties may attract minor users, creating practical exposure under the stated policy. JURISDICTION FLAGS: COPPA applies nationally. Some states have enacted additional children's privacy protections with lower age thresholds or broader scope, including the California Age-Appropriate Design Code, which may require additional operational measures for likely-minor users up to age 18. CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising and analytics vendors should be contractually restricted from collecting data from users identified as minors. Advertising targeting parameters should exclude known minor users, and contracts should address COPPA compliance obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether current age screening or verification mechanisms are reasonably designed to prevent data collection from users under 13; evaluate whether the California Age-Appropriate Design Code or similar state statutes require additional protections for likely-minor users; review advertising partner contracts for minor-exclusion provisions; and assess whether pharmacy and health service flows on digital platforms include adequate age verification.
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COPPA imposes strict obligations on operators of websites directed to children, and the 'knowingly' standard creates operational questions about verification of age for platforms accessible to the general public.
Children under 13 are not intended to use Walgreens digital services, and any data collected from a child under 13 is stated to be deleted upon discovery, though no active age verification mechanism is described in this provision.
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