Friday, Jul 24, 2026 The claims desk. Receipts included. POWERED BY LENZ ↗
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LEGAL

The Claim

In the United States, a developer can legally show contextual (non-behavioral) ads in a mobile game directed to children aged 6–15 without obtaining verifiable parental consent, provided no personal data is collected or disclosed to third parties for advertising purposes.

Verified by Lenz ·

The Short Version

The core claim is substantially accurate. Under COPPA, a child-directed mobile game may serve purely contextual ads to under-13 users without verifiable parental consent when personal information is not collected, used, or disclosed for behavioral advertising. The main caveat is that COPPA covers only children under 13; for ages 13–15, the result is generally the same, but for a different legal reason, and other laws or platform rules may still apply.

Caveats

  • COPPA’s parental-consent framework applies only to children under 13; ages 13–15 are outside COPPA, so the legal basis is different.
  • This is not a blanket exemption: if an ad SDK collects persistent identifiers such as IP addresses or device IDs beyond internal operations, COPPA obligations can change.
  • Even without parental consent, operators may still need COPPA-compliant privacy disclosures and must check state privacy laws and app-store requirements.

The Receipts

  1. Children's Online Privacy Protection Rule ('COPPA')

    Federal Trade Commission

  2. 16 CFR Part 312 -- Children's Online Privacy Protection Rule

    eCFR

  3. Complying with COPPA: Frequently Asked Questions

    FTC

  4. Children's Online Privacy Protection Rule (COPPA) Compliance

    Hyperproof

  5. Children's Online Privacy Protection Act: COPPA

    Kiteworks

  6. COPPA Act: Children's Online Privacy Protection Guidelines

    National Credit Union Administration (NCUA)

  7. New FTC COPPA Rule Update Does Little for Parents to Protect Children Online

    IITF

  8. Children's Privacy

    Electronic Privacy Information Center (EPIC)

  9. Are the apps your children use illegally marketing to them?

    Federal Trade Commission (via Liberty Bank summary of FTC action)

  10. FTC Finalizes COPPA Rule Changes, New Rule Takes Effect in June

    Venable

+ 18 more sources — see the full list on Lenz

Filed Under

Children's Online Privacy Protection ActFederal Trade CommissionUnited States

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