Does COPPA apply to apps and games used by children?

What the Law Says

The Children's Online Privacy Protection Act (COPPA) defines who and what it covers — including digital services used by kids.

COPPA applies to operators of websites, online services, mobile apps, and games that are either directed to children under 13 or have actual knowledge they’re collecting personal information from children under 13.

The law defines 'operator' broadly — it includes any person or entity that collects personal information online from users of a website or online service, including apps and games. It also covers third parties (like ad networks or analytics providers) that collect data on those platforms.

COPPA defines 'personal information' to include names, addresses, email addresses, phone numbers, Social Security numbers, geolocation data precise enough to identify a street name and city, photos, videos, audio files containing a child’s image or voice, and persistent identifiers (e.g., cookies or device IDs) used to track a user over time and across sites or services.

Statutory Text

The term 'operator' means any person who operates a website located on the Internet or an online service and who collects or maintains personal information from or about the users of or visitors to such website or online service, or on whose behalf such information is collected or maintained.

— Children's Online Privacy Protection Act, 15 U.S.C. § 6501(4) — Definitions

Statutory Text

The term 'personal information' means individually identifiable information about an individual collected online, including... (i) a first and last name; (ii) a home or other physical address... (iii) an electronic mail address... (iv) a telephone number... (v) a Social Security number... (vi) information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier...

— Children's Online Privacy Protection Act, 15 U.S.C. § 6501(8) — Definitions

Sources