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The policy states that Writer's services are not directed to users under 16, that the company does not knowingly collect personal information from persons under 16, and that it will delete such information if discovered.
This analysis describes what Writer'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
The policy sets a minimum age of 16 rather than 13, which exceeds the minimum threshold under the U.S. Children's Online Privacy Protection Act (COPPA) and aligns with the minimum age threshold established under GDPR Article 8 for information society services in jurisdictions that have not lowered the default age.
Under this clause, users under 16 are not permitted to use Writer's services, and any personal information collected from a user under 16 will be deleted upon discovery. Parents or guardians should contact privacy@writer.com if they believe their child has submitted personal information.
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"Our Services are not directed to persons under 16. We do not knowingly collect or process personally identifiable information from children under 16. If a parent or guardian becomes aware that their child has provided us with personally identifiable information without their consent, they should contact us at privacy@writer.com. If we become aware that a child under 16 has provided us with such information, we will take steps to delete this information from our files.Excerpt from Writer's Privacy Policy
REGULATORY LANDSCAPE: This provision engages COPPA, which requires verifiable parental consent for collection of personal information from children under 13, and GDPR Article 8, which sets a default minimum age of 16 for processing personal data of minors in the context of information society services. By setting a minimum age of 16, the policy exceeds COPPA's statutory minimum and aligns with GDPR's default. The FTC holds COPPA enforcement authority; EU data protection authorities hold authority under GDPR Article 8. GOVERNANCE EXPOSURE: Low. The 16-year minimum age threshold creates a more conservative compliance posture than COPPA requires. However, the policy does not describe technical age verification mechanisms, relying instead on a self-attestation or reactive deletion approach. JURISDICTION FLAGS: EU member states that have lowered the GDPR Article 8 age to 13 (such as the UK under the UK GDPR, which sets 13 as the default for information society services) may create inconsistency between the policy's 16-year threshold and local law. In the U.S., the FTC's enforcement focus on age assurance mechanisms may be relevant as regulatory guidance on age verification continues to evolve. CONTRACT AND VENDOR IMPLICATIONS: No specific contract or vendor implications arise from this provision beyond standard data deletion obligations with processors. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether technical age assurance mechanisms are in place to operationally support the 16-year minimum age assertion, as reactive deletion alone may not satisfy evolving regulatory expectations under COPPA or GDPR in the event of an enforcement inquiry.
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The policy sets a minimum age of 16 rather than 13, which exceeds the minimum threshold under the U.S. Children's Online Privacy Protection Act (COPPA) and aligns with the minimum age threshold established under GDPR Article 8 for information society services in jurisdictions that have not lowered the default age.
Under this clause, users under 16 are not permitted to use Writer's services, and any personal information collected from a user under 16 will be deleted upon discovery. Parents or guardians should contact privacy@writer.com if they believe their child has submitted personal information.
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