The notice states that Zendesk's services are not directed to children under 16 and that Zendesk does not knowingly collect personal data from that age group, with a mechanism to report and delete such data if discovered.
This analysis describes what Zendesk'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 Zendesk's age threshold at 16 for data collection purposes, engaging COPPA requirements in the US for children under 13 and GDPR Article 8 requirements for children under 16 in EU member states that have not lowered the threshold, which varies by country.
The agreement states that Zendesk does not knowingly collect data from users under 16, and provides privacy@zendesk.com as the contact to report and request deletion of any such data. This threshold is set at 16 rather than the US COPPA threshold of 13.
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"Our Services are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us at privacy@zendesk.com and we will take steps to delete such information.— Excerpt from Zendesk's Zendesk Privacy Policy
(1) REGULATORY LANDSCAPE: COPPA in the US requires verifiable parental consent for collection of personal data from children under 13, enforced by the FTC. GDPR Article 8 sets the age of digital consent at 16 by default but permits member states to lower it to 13. Zendesk's threshold of 16 satisfies GDPR's default requirement but may exceed COPPA's 13-year threshold for US purposes. (2) GOVERNANCE EXPOSURE: Low for Zendesk's own marketing properties given the B2B nature of its primary services. However, if Zendesk's platform is deployed by business customers in consumer-facing contexts, the business customer as controller bears responsibility for assessing whether children's data is processed through the platform and whether COPPA or GDPR Article 8 obligations apply. (3) JURISDICTION FLAGS: EU member states that have set the digital consent age below 16 (such as the UK at 13, Germany at 16, and others varying between 13 and 16) should be noted. US-based organizations should confirm that Zendesk's practices satisfy COPPA requirements for their specific use case. (4) CONTRACT AND VENDOR IMPLICATIONS: Business customers deploying Zendesk in consumer-facing contexts should assess whether their service agreement with Zendesk addresses children's data and whether Zendesk's subprocessor practices are compatible with COPPA or GDPR Article 8 requirements applicable to their platform. (5) COMPLIANCE CONSIDERATIONS: Organizations in education, children's media, or consumer services deploying Zendesk should conduct a specific assessment of children's data flows through Zendesk systems and confirm that appropriate safeguards are in place at the business customer level.
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This provision establishes Zendesk's age threshold at 16 for data collection purposes, engaging COPPA requirements in the US for children under 13 and GDPR Article 8 requirements for children under 16 in EU member states that have not lowered the threshold, which varies by country.
The agreement states that Zendesk does not knowingly collect data from users under 16, and provides privacy@zendesk.com as the contact to report and request deletion of any such data. This threshold is set at 16 rather than the US COPPA threshold of 13.
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