Xfinity states that its services are not intended for children under 13, and it claims it will delete any data collected from children under 13 without parental consent if discovered.
This analysis describes what Xfinity'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
Given that Xfinity provides household internet, cable, and home security services that are routinely used by all members of a household including children, the 'not directed to children under 13' statement warrants practical scrutiny.
Interpretive note: The practical application of COPPA to household internet and cable accounts where children are incidental users depends on FTC guidance and enforcement posture, which has evolved; the 'not directed to children' framing may not be sufficient if Xfinity offers child-targeted features under the same account.
Children in households with Xfinity services may have their internet activity, viewing history, or other data collected under the general household account, raising questions about COPPA compliance in shared service environments.
How other platforms handle this
American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...
When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...
We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.
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"We are committed to protecting the privacy of children. Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If we learn we have collected personal information from a child under 13 without parental consent, we will take steps to delete it.— Excerpt from Xfinity's Comcast Privacy Policy
REGULATORY LANDSCAPE: The Children's Online Privacy Protection Act (COPPA), enforced by the FTC, requires verifiable parental consent before collecting personal information from children under 13, imposes data minimization requirements, and limits retention and use of children's data. The FTC has brought enforcement actions against both consumer technology companies and ISPs for COPPA violations where children's data was collected through general service accounts. Some state laws extend analogous protections to minors under 16 or 18. GOVERNANCE EXPOSURE: Medium. The household service context is operationally distinct from children's apps or platforms, and the 'not directed to children' framing is consistent with standard industry practice for general audience services. However, where Xfinity provides parental control features, kids' content sections, or educational services under the same account, the line between general audience and child-directed content may be less clear, which can affect COPPA applicability. The FTC's 2023 COPPA amendments strengthen the 'actual knowledge' standard. JURISDICTION FLAGS: COPPA applies federally to all U.S. child users. California's Age-Appropriate Design Code (AB 2273, currently subject to litigation) may impose additional obligations. The UK Children's Code (Age Appropriate Design Code) applies to services likely to be accessed by children in the UK, which is relevant given the policy's EEA and UK notice. Some state laws (Delaware, Maryland) have enacted analogous children's privacy protections. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics vendors that may receive data from household accounts where children are present should be contractually prohibited from using such data for behavioral advertising targeting. Parental controls and child profile features should be reviewed for COPPA compliance. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether household account data collection practices that may capture children's activity satisfy COPPA's actual knowledge standard and whether parental consent mechanisms are available and promoted. Review whether the policy's children's data statement is sufficient or whether additional COPPA-specific notices are required.
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Given that Xfinity provides household internet, cable, and home security services that are routinely used by all members of a household including children, the 'not directed to children under 13' statement warrants practical scrutiny.
Children in households with Xfinity services may have their internet activity, viewing history, or other data collected under the general household account, raising questions about COPPA compliance in shared service environments.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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