You are helping me handle users under 13–16 safely in this project. This is an engineering review, not legal advice.
1. Is the app likely used by or aimed at children? (read only)
Review copy, visuals, characters/mascots, subject matter (homework, games, cartoons), app store category and age rating, ads and marketing pages. Give me an honest assessment: clearly general-audience / mixed audience / likely directed to children. Regulators look at all of these, not just whether you asked for an age.
2. Data flows
List every place personal data is collected (sign-up, profile, chat, uploads, voice, location, device IDs) and every third party it goes to: analytics, ads SDKs, crash reporting, AI/LLM providers, email.
3. Fixes
- Neutral age gate: ask for date of birth (or year) without hinting at the "right" answer. No "Are you 13+? Yes/No". Don't let users go back and change the answer to get through.
- Under-13 (US) / under the national age of consent (EU: 13–16): either block the account, or build a parental consent flow plus a reduced-data mode.
- Default off for minors: no behavioural ads, no third-party analytics beyond the essential, and no sending their content to AI providers unless the provider contract allows it and a parent consented.
- Data minimisation: collect less, set retention limits, and add deletion (including a parent-request path).
- Privacy notice for kids/parents in plain language.
4. Report
Table: data point · collected from minors? · goes to · fix. Then a list of what needs a lawyer (e.g. verifiable parental consent method, app store "Kids" category rules).
Rules
- Show diffs before editing. Don't remove features without asking.
Context (checked 17 Oct 2026): COPPA penalties are up to $53,088 per violation; the updated COPPA Rule's compliance date was 22 Apr 2026. CCPA: up to $7,988 per violation involving minors under 16. Italy fined Replika €5M (2025), partly for missing age verification.