COPPA Compliance Guide: Age Gating, Consent, and FTC
Practical COPPA roadmap for business owners: age gating, verifiable parental consent, and FTC basics, plus LegalDocs.ai tools to document compliance.
COPPA, the Children's Online Privacy Protection Act (15 U.S.C. §§ 6501-6506; 16 C.F.R. Part 312), applies if your site or app is directed to children under 13, or you knowingly collect their data. Start with a neutral age gate: ask for full birthdate or age without nudging users to claim they're 13+. Don't block solely for selecting "under 13"; instead route them to parent workflows. Collect the minimum data needed, and publish a clear, child-friendly privacy notice and parental contact options.
Before collecting personal information from a child, obtain verifiable parental consent under 16 C.F.R. § 312.5. Approved methods include small credit/debit card charge, government ID check with facial similarity, knowledgeable questions, signed consent form via fax/scan, or live video call; "email plus" is limited to internal-use data. Send direct notice to parents describing what you collect, how it's used, and their rights, per § 312.4. Keep time-stamped consent records, and allow easy review, deletion, and withdrawal.
COPPA Compliant Ad SDKs for Mobile Games
Ad monetization is the most common COPPA failure point for mobile games. Choosing COPPA compliant ad SDKs means configuring each network's child-directed mode before any ad request: AdMob's tag_for_child_directed_treatment flag, Unity Ads and ironSource/Unity LevelPlay COPPA metadata, and AppLovin's child-directed settings all disable behavioral targeting and limit data collection for under-13 audiences. Serve contextual ads only, pass the child-directed signal on every request (not just at install), and confirm each SDK's certified configuration in writing from the vendor. App store programs — Apple's Kids Category and Google Play's Families policy — impose their own approved-SDK lists on top of COPPA.
The FTC enforces COPPA, with penalties per violation and mandated audits. Build a defensible program: conduct a COPPA risk assessment, vet adtech and SDK vendors, disable behavioral ads for under-13s, and implement data minimization, retention limits, and security (§ 312.3). Consider an FTC-approved Safe Harbor program (16 C.F.R. § 312.11). LegalDocs.ai provides age-gate language, parental consent flows, notices, vendor clauses, and audit-ready logs, so you can operationalize compliance, train staff, and respond quickly to complaints or investigations.