What Privacy Laws Apply When My App Collects Kids' Data?

Building an app that collects childrens data is—well, its a bit like walking through a minefield, honestly. The rules are strict, the penalties can be massive, and one wrong move can sink your entire project before it even launches. I've worked on apps across all kinds of industries over the years, but the ones that involve kids always need extra attention because children's privacy laws exist for very good reasons and regulators take them seriously.

Here's the thing though: lots of developers think they don't need to worry about these regulations because their app "isn't really for kids." But if children under 13 might use your app, even if they aren't your primary audience, you still need to comply with children's privacy laws. That includes apps for general audiences, social platforms, games that appeal to multiple age groups—basically anything a child could access and use. And the definition of "collecting data" is broader than most people realise; it includes device identifiers, location data, photos, usernames, pretty much anything that could identify or track a user.

The question isn't whether your app is marketed to children, but whether children might actually use it and whether you're collecting any of their personal information

COPPA compliance in the US is just the starting point too. You've got GDPR in Europe with its own rules about processing childrens data, and countries like the UK, Australia and others have their own regulations on top of that. Sure, it sounds complicated—and it is—but understanding these laws isnt optional if you want to operate legally and protect your business from regulatory action. Getting parental consent right, limiting what data you collect, working with third-party services that are also compliant...all of these pieces need to fit together properly or you're putting your app at risk.

Understanding COPPA and Why It Matters

COPPA stands for the Children's Online Privacy Protection Act, and if your app collects any data from kids under 13, you need to know about it. I mean it—this isn't optional stuff. The law came into effect back in 2000 in the United States, and its designed to protect children's personal information online. Breaking COPPA rules can cost you up to £40,000 per violation, and trust me, the Federal Trade Commission doesn't mess about when it comes to protecting kids.

Here's the thing though—COPPA applies even if you didn't mean to collect kids data. If your app is directed at children, or if you know you're collecting information from users under 13, COPPA rules kick in automatically. And "directed at children" is broader than you might think; the FTC looks at things like your apps subject matter, visual content, use of animated characters, whether you advertise to kids, and even the age of your actual users. So that fitness app you built for adults? If loads of 10-year-olds are using it and you know about it, COPPA suddenly becomes your problem.

What counts as personal information is pretty broad too—names, email addresses, photos, location data, IP addresses, device identifiers, even persistent cookies. Basically anything that can identify a specific child. But here's what makes it tricky: even if you're just using Google Analytics on your kids app, that collects data, which means you need to comply with COPPA rules about how that data is handled and get parental consent first.

I've seen app developers get caught out because they assumed COPPA didn't apply to them. Don't make that mistake; if kids are using your app, you need to understand these rules inside and out.

Age Verification Methods That Actually Work

Right, let's talk about age gates—because honestly, most of them are absolutely rubbish. You know the ones: "Are you 13 or older?" with two big buttons. A five-year-old can tap "Yes" and suddenly you're collecting data from someone who should be protected under children's privacy laws. Its not just bad practice, it's potentially illegal depending on your jurisdiction.

The tricky bit here is that age verification needs to be effective without creating friction that drives users away. I mean, if you make the process too complicated, even legitimate users will abandon your app before they've given it a proper chance. But here's the thing—there are methods that actually work if you implement them correctly; you just need to know which ones make sense for your specific app.

Methods That Hold Up to Scrutiny

Neutral age screening is your baseline. Instead of asking "Are you 13 or older?" ask users to enter their birth date or select their age from a dropdown. This creates what's called "knowledge-based verification" and its slightly harder for kids to fake. Sure, they can still lie, but you've made a reasonable effort and that matters from a compliance standpoint.

Email verification adds another layer—when someone claims to be over the age threshold, send a verification email that requires clicking through. Kids under 13 often don't have their own email addresses, which naturally filters out some underage users. And if they're using a parent's email? Well, that opens a conversation between parent and child about what they're signing up for.

Credit card verification is the gold standard for age gating but also the most controversial because it adds serious friction. You're not actually charging anything; you're just verifying that someone has access to a payment method, which typically indicates they're an adult. I've seen this work brilliantly for apps in regulated industries but it does reduce conversion rates pretty dramatically.

What About AI and Facial Recognition?

Some platforms are experimenting with AI-based age estimation that analyses selfies to guess someone's age. The technology has improved a lot but its still not perfect—and more importantly, it raises its own privacy concerns. Do you really want to collect facial data just to verify age? That's a whole new can of worms from a data protection perspective. I generally advise clients to avoid this unless they're in a highly regulated industry where the trade-off makes sense.

Document your age verification process thoroughly in your privacy policy and your internal compliance records. If regulators come knocking, you need to show you made reasonable efforts to prevent underage data collection—even if your system isn't foolproof.

The reality is that no age gate is completely foolproof; kids are resourceful and if they want to get past your verification, many will find a way. What matters legally is that you've implemented reasonable measures appropriate to your app's risk level. A casual gaming app doesn't need the same rigorous verification as a social networking platform where kids might be exposed to strangers.

One approach I've seen work well combines multiple methods: start with birth date entry, then add email verification for users who indicate they're close to the age threshold (say, 13-15 years old), and implement behavioural monitoring that flags accounts that seem inconsistent with their stated age. If a "25-year-old" is accessing your app during school hours every day and their usage patterns match typical child behaviour, that's worth investigating.

Here's what you should consider when choosing your verification method:

• Your app's target audience and how tech-savvy they are
• The sensitivity of data you'll be collecting from users
• How much friction your conversion funnel can tolerate
• What your competitors are doing (if everyone in your space uses email verification, users expect it)
• Your budget for implementing and maintaining the verification system
• Whether your app has features specifically designed for children vs. being a general audience app

And look, here's something that trips people up constantly: age verification isn't a one-time thing. If you're running a mixed-audience app where some features are age-restricted, you need to re-verify or gate those specific features. Just because someone verified they were 13 when they signed up doesn't mean you can forget about COPPA compliance—you need ongoing monitoring and appropriate restrictions based on user age throughout their entire time using your app.

What You Need in Your Privacy Policy

Right, so you've determined that COPPA applies to your app—now you need to write a privacy policy that actually meets the legal requirements. And I'm not going to sugarcoat it; this isn't the fun part of app development. But its absolutely necessary, and getting it wrong can cost you dearly.

Your privacy policy needs to be clear and comprehensive. I mean really clear—like explaining it to a parent who's never read legalese before. The FTC requires that you list exactly what information you're collecting from kids, why you're collecting it, and how you'll use it. This means breaking down everything: usernames, location data, photos, device identifiers, cookies, the lot. You cant just say "we collect some data to improve our service"—that won't cut it anymore.

Making Your Policy Actually Readable

Here's the thing though—your policy needs to be accessible before any data collection happens. Not buried three levels deep in your app settings. The FTC wants it prominent and easy to find, which usually means linking to it directly from your apps main screen or during the onboarding process. And if your app is targeted at kids under 13, you need a separate section specifically about childrens privacy; its not enough to have one general policy that covers everyone.

What Parents Actually Need to Know

You also need to explain parents rights clearly: how they can review their childs data, how they can ask you to delete it, and how they can revoke consent. I've seen so many apps that technically include this information but bury it in paragraph 47 of dense legal text. Don't do that. Make it obvious—parents are busy and they need to understand their options quickly. Include a direct contact method (email address or phone number) where parents can reach someone who can actually help them with these requests, not just an automated response system.

Getting Parental Consent Right

So you've determined that you need parental consent—now comes the tricky bit. COPPA doesn't just say "get permission from parents" and leave it at that; it specifies how you need to get that consent, and honestly, its more complex than most people expect.

The law requires what they call "verifiable parental consent" which basically means you need to prove that an actual adult gave permission, not just a kid pretending to be their mum. I've seen developers try to cut corners here with a simple checkbox that says "I'm over 18" but that won't fly—COPPA wants something more substantial.

Methods That Meet the Standard

There are several approved methods for getting consent and they all involve some friction (which is intentional, by the way). You can use credit card verification, where parents provide payment details; digital signatures through services like DocuSign; video conferencing to verify identity; or government-issued ID checks. Some apps use a "small monetary charge" method where parents make a tiny payment to prove they're adults with payment methods.

The consent mechanism you choose needs to balance security requirements with user experience—make it too difficult and parents will abandon the process, make it too easy and you're not meeting legal requirements

Here's something that trips people up: you need to get consent before collecting any data, not after. That means your app cant collect information during onboarding and then ask for permission later. Build your flow so consent comes first, then data collection begins. And keep records of that consent—if regulators come knocking, you'll need to prove you got proper permission from each child's parent or guardian. Store timestamps, IP addresses, and the method used for verification.

Data Collection Limits for Children Under 13

Right, this is where things get properly strict—and for good reason. COPPA doesnt just make you ask for permission before collecting kids data; it actually limits what data you can collect in the first place. You cant just get parental consent and then hoover up everything you want. There are real boundaries here.

The golden rule? You can only collect what's necessary for your app to function. Thats it. No "nice to haves" or "might be useful later" stuff. I mean, if you're running a drawing app for kids, you dont need their location data or contact lists, right? COPPA requires what's called data minimisation—collect the minimum amount needed and nothing more.

What You Absolutely Cannot Collect

Here's what's off-limits or requires extra careful handling:

• Precise geolocation data (unless its genuinely needed for the app's core function)
• Photos, videos or audio recordings beyond what the app's purpose requires
• Contact information from the child's device
• Persistent identifiers used for behavioural advertising
• Any data that could be used to contact the child directly
• Screen names or usernames that function as online contact information

The Retention Problem

But here's the thing—its not just about what you collect, it's also about how long you keep it. You need to delete childrens personal information once its no longer needed for the purpose it was collected. Not when you feel like it. Not when it becomes inconvenient. When it's no longer needed. Period.

I've seen apps get into trouble because they kept user data "just in case" or for analytics that werent necessary. Don't do that. Set up automatic deletion policies and stick to them. Your future self will thank you when the FTC comes knocking—trust me on this one.

International Privacy Laws Beyond COPPA

Right, so if you think COPPA is the only law you need to worry about—well, I hate to break it to you but there's a whole world of privacy regulations out there. And they can be quite different from each other, which is honestly a bit mad when you're trying to build an app that works globally.

The big one in Europe is GDPR, which doesn't just cover kids but has specific rules about children's data. Under GDPR, the age of consent varies by country—it can be anywhere from 13 to 16, depending on where your users are. In the UK its 13, in Germany its 16, and honestly keeping track of all these different ages is enough to make your head spin. But here's the thing—you need to comply with the laws where your users are, not just where your business is based. If you've got kids in Germany downloading your app, you need to follow German rules for those users.

What Makes GDPR Different

GDPR is stricter than COPPA in some ways; it requires "clear and plain language" that kids can actually understand, and the fines are massive—up to 4% of your global annual revenue. I mean, that's not pocket change for anyone. The regulation also limits what data you can collect based on "legitimate interest" and basically says you cant process kids data unless its necessary for the service you're providing.

Other Countries Getting Serious About Kids Privacy

Australia has the Privacy Act which applies special protections to children under 18. Canada has PIPEDA. California (yes I know its not a country but it might as well be for privacy laws!) has the California Consumer Privacy Act that works alongside COPPA. And more countries are adding their own rules every year—its a moving target really.

If your app will be available internationally, work with a privacy lawyer who understands multiple jurisdictions. The cost of getting this wrong far outweighs the legal fees, trust me on that one.

Third-Party Services and Kids' Data

Here's where things get a bit tricky—most apps don't just collect data themselves, they also use third-party services that might be collecting data too. Analytics tools, advertising networks, social media plugins, crash reporting services... the list goes on. And when your app is aimed at kids? You're responsible for every single piece of data that any of these services collect.

I mean, think about it. You might have built a perfectly compliant app that follows all the rules, but if you've integrated Google Analytics or Facebook's SDK without properly configuring them, you could be in violation of COPPA without even knowing it. Its honestly one of the most common mistakes I see—developers assume that because they're not directly collecting the data, they're not responsible for it. Wrong.

Before you integrate any third-party service into a kids app, you need to do your homework. Ask yourself: does this service collect personal information? Can I turn off data collection for users under 13? Does the service provider comply with COPPA themselves? Many major providers now offer "COPPA-compliant modes" but you need to actually enable them—they dont switch on automatically.

What to Check Before Integration

• Review the third-party service's privacy policy and terms of service
• Confirm they have a COPPA-compliant mode or child-directed version
• Check if the service collects persistent identifiers like device IDs or advertising IDs
• Verify whether you can disable behavioural advertising for child users
• Make sure the service won't use kids data for their own purposes
• Document everything in your own privacy policy

Some third-party services simply aren't suitable for kids apps at all. Social login buttons, ad networks that use behavioural targeting, chat services that connect users with strangers—these need to be carefully evaluated or avoided entirely. The safest approach? Keep third-party integrations to an absolute minimum when building for children.

Conclusion

Look, building apps that collect kids data isn't something you can just wing and hope for the best. I've seen too many developers—talented ones, really—get caught out because they didn't take children's privacy laws seriously enough. And the consequences? They're not pretty. We're talking about hefty fines, app store removals, and damaged reputations that take years to rebuild.

But here's the thing—COPPA compliance and following kids app regulations doesn't have to be this massive headache that keeps you up worrying. Its actually pretty straightforward once you understand what's required. You need proper age verification, you need clear privacy policies written in language parents can actually understand, and you need verifiable parental consent before collecting any personal information from children under 13. Thats the foundation.

The bit that trips people up most? Its usually the third-party services. Your analytics tools, your advertising networks, even that helpful crash reporting service you installed—they all need to be COPPA compliant too. One dodgy SDK can undermine everything else you've done right. I mean, you could have perfect data collection rules and parental consent processes, but if your ad network is tracking kids without permission, you're still in violation.

And don't forget that children's privacy laws extend way beyond just COPPA if you're operating internationally. GDPR-K in Europe, PIPEDA in Canada—they all have their own requirements that you need to factor in from day one, not as an afterthought when you decide to expand.

The truth is, protecting kids privacy isn't just about avoiding legal trouble (though that's obviously important). It's about doing the right thing. Parents trust us with their childrens data; breaking that trust isn't worth whatever shortcuts might save you a bit of development time. Build it properly from the start, stay informed about regulatory changes, and you'll sleep better knowing you've built something that's both successful and responsible.