The policy states that Walgreens services are not directed to children under 13, that the company does not knowingly collect personal information from this age group, and that such information will be deleted upon discovery.
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
This provision establishes a COPPA-compliant framework for the primary digital services, but the pharmacy and health context presents a specific operational consideration: minors may be represented in prescription or family health account contexts, which may require additional protections beyond COPPA's baseline requirements.
Interpretive note: The policy does not address how minor-related data arising in family account or prescription management contexts is handled, which may require separate regulatory analysis.
The severity was downgraded from medium to low, and the language was slightly softened from 'will delete it' to 'will take steps to delete that information.'
View full change record →Under this provision, Walgreens' digital services are not intended for users under 13 and the company states it will delete personal information of children under 13 upon discovery. Family account or prescription contexts involving minors are not separately addressed in this provision.
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The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }
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"Our 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 become aware that we have collected personal information from a child under 13, we will take steps to delete that information.— Excerpt from Walgreens's Walgreens Privacy Policy
1. REGULATORY LANDSCAPE: COPPA, enforced by the FTC, prohibits collection of personal information from children under 13 without verifiable parental consent. HIPAA's minor patient privacy provisions may apply in pharmacy contexts where prescription records of minors are accessed by family account holders. 2. GOVERNANCE EXPOSURE: Medium. The policy's COPPA disclaimer applies to direct digital service interactions. However, pharmacy and family health account features may result in incidental collection of minor-related data in contexts not clearly addressed by this provision. The FTC actively enforces COPPA against platforms that fail to implement adequate age-screening mechanisms. 3. JURISDICTION FLAGS: COPPA applies federally in the US. Some states including California (CPPA Age-Appropriate Design Code, pending implementation) and states with children's online privacy legislation may impose additional obligations. HIPAA minor patient provisions vary by state law regarding parental access to minor health records. 4. CONTRACT AND VENDOR IMPLICATIONS: Service providers with access to platform data should be assessed for COPPA compliance. Family account or prescription management features should be reviewed to ensure minor data is processed consistently with COPPA and applicable state requirements. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether age-gate or age-screening mechanisms are implemented for account creation and digital service access. Pharmacy and family account features should be reviewed to determine whether minor health data is processed consistently with HIPAA minor patient provisions and applicable state law.
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This provision establishes a COPPA-compliant framework for the primary digital services, but the pharmacy and health context presents a specific operational consideration: minors may be represented in prescription or family health account contexts, which may require additional protections beyond COPPA's baseline requirements.
Under this provision, Walgreens' digital services are not intended for users under 13 and the company states it will delete personal information of children under 13 upon discovery. Family account or prescription contexts involving minors are not separately addressed in this provision.
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