Best examples of COPPA marketing restrictions for children marketers must know

Real‑world examples of COPPA marketing restrictions for children

COPPA is often described as a “privacy law,” but for anyone in growth, product, or advertising, it’s just as much a marketing law. The Federal Trade Commission (FTC) has made it clear: if your online service is directed to children under 13, or you knowingly collect their personal information, your marketing playbook changes dramatically.

To make this concrete, let’s walk through real examples of COPPA marketing restrictions for children that regularly show up in enforcement actions, guidance, and industry practice.

Example of banned behavioral advertising to kids under 13

The clearest example of COPPA marketing restrictions for children is the limit on behavioral advertising. If your app or site is child‑directed, you generally cannot:

• Track a child across apps or websites over time using persistent identifiers (like ad IDs, cookies, device IDs) for targeted advertising without verifiable parental consent.
• Build ad profiles based on a child’s gameplay history, viewing habits, or browsing behavior.
• Use third‑party ad networks that automatically track and profile users, unless they are configured in a strictly contextual, non‑tracking mode.

In practice, that means a kids’ math game cannot legally use a standard mobile ad SDK that profiles users to show “interest‑based” or “personalized” ads. The FTC’s actions against YouTube in 2019 and Epic Games (Fortnite) in 2022–2023 highlighted how ad tech that looks normal in adult products becomes risky when children are involved.

For a privacy policy template, this translates into clear disclosures that you do not use children’s data for behavioral advertising, or that you only do so with verified parental consent and opt‑out options, consistent with FTC COPPA guidance.

Examples of COPPA marketing restrictions for children on email and direct messaging

Another set of examples of COPPA marketing restrictions for children involves email and messaging. COPPA allows collecting a child’s online contact information for limited purposes, but it sharply restricts how you can use it for marketing:

• If a child enters an email to sign up for a game, you may use it for account‑related notices (password resets, service updates), but not to send ongoing promotional newsletters unless you have verifiable parental consent.
• If you run a kids’ art contest and collect email addresses to notify winners, COPPA expects you to delete those addresses after the contest, not roll them into a promotional mailing list.
• If a child contacts customer support, you can respond, but you cannot convert that email into a marketing contact without parental permission.

A COPPA‑aware privacy policy should spell out these limits: that children’s contact information is not used for promotional campaigns without parental authorization, and that any temporary use (for contests or one‑time responses) is time‑bound and then deleted. The FTC explains these limited exceptions in its FAQs for businesses (see the FTC’s COPPA FAQ).

Best examples of in‑app purchase and monetization restrictions

Monetization is marketing too. Several high‑profile settlements in 2022–2023 show how COPPA intersects with in‑app purchases and upsell tactics directed at children:

• Games that prompt kids repeatedly to buy virtual currency or upgrades, especially when the design nudges them to think they must pay to keep playing.
• Screens that blur the line between gameplay and advertising, making it hard for a child to tell when they are being marketed to.
• “One‑click” purchase flows where a child can spend real money without a parent’s clear involvement.

While COPPA doesn’t ban in‑app purchases, it does treat payment information and persistent identifiers as personal information. If you’re collecting that data from a child, your privacy policy must be transparent about what is collected, how it’s used, and whether it’s tied to marketing or upsell campaigns.

The Epic Games settlement, for example, included allegations about dark patterns and unauthorized charges involving children. While that case also involved other laws, it’s a warning sign: aggressive monetization directed at kids can quickly draw regulatory attention in the COPPA context.

Examples of COPPA marketing restrictions for children on social sharing and user‑generated content

Social features are a minefield for children’s apps. Here are examples of COPPA marketing restrictions for children when it comes to sharing and user‑generated content:

• A kids’ game that encourages children to share their username or profile publicly and then uses those profiles for cross‑promotion or influencer‑style campaigns.
• A platform that lets children post photos or videos and then repurposes that content in marketing materials without parental consent.
• “Invite a friend” features that ask a child to enter friends’ email addresses so the service can send promotional messages.

Under COPPA, collecting a friend’s email from a child for viral marketing is heavily restricted. The rule allows a narrow “one‑time contact” exception, but it is not a free pass for referral marketing programs aimed at kids. If you want social features, you typically need either:

• Strong age‑gating and separate experiences for under‑13 and 13+ users, or
• Verifiable parental consent before enabling sharing, profiles, or public posting.

Your privacy policy template should describe whether social features are available to children at all, and, if so, what safeguards and parental controls apply.

Contextual vs behavioral ads: practical examples include ad tech configuration

One of the best examples of COPPA marketing restrictions for children that trips up product teams is the difference between contextual and behavioral advertising:

• Contextual ads are based only on the content being viewed at that moment (for example, showing a puzzle toy ad in a puzzle game). They do not rely on tracking the child over time or across services.
• Behavioral ads (sometimes called interest‑based or personalized ads) use data about the child’s prior behavior across sites or apps to choose which ad to show.

COPPA allows contextual ads on child‑directed services without parental consent, as long as persistent identifiers are used only to support the current session and not to track the child over time. But behavioral ads require verifiable parental consent.

Real examples include:

• A streaming app for kids that configures its ad SDK in “child‑directed” mode, turning off personalized ads and cross‑app tracking, and disclosing in its privacy policy that only contextual advertising is used.
• A game studio that maintains two ad configurations: one for general‑audience titles (with personalized ads) and one for kids’ titles (contextual only, with limited data collection) to stay on the right side of COPPA.

The FTC and state regulators have signaled that simply labeling your app “for families” while running standard behavioral ad tech is not enough; your configuration and disclosures must match your marketing claims.

Examples of COPPA marketing restrictions for children in analytics and A/B testing

Marketers love data. COPPA limits how much of that data you can collect from children, and how you can use it:

• Analytics tools that create detailed user profiles, track cross‑app behavior, or combine data with third‑party datasets may violate COPPA if used on child‑directed services without parental consent.
• A/B tests that rely on persistent identifiers to track a child’s behavior over time for marketing optimization can be problematic if they go beyond what’s reasonably necessary to provide the service.

The law expects you to follow a data‑minimization approach: collect only what you reasonably need for the child’s activity, not everything you’d like for growth experiments. In your privacy policy template, you should:

• Identify which analytics tools are used in child‑facing experiences.
• Explain whether they are configured in a limited, COPPA‑compliant mode (for example, IP anonymization, no cross‑site tracking, no sharing for advertising).
• Clarify that children’s data is not combined with third‑party data for marketing or profiling.

2024–2025 trends shaping COPPA marketing restrictions

COPPA itself is a 1998 law, but enforcement and expectations in 2024–2025 are very current. Some trends that directly affect examples of COPPA marketing restrictions for children:

• Aggressive enforcement and higher penalties. The FTC and state attorneys general continue to pursue large platforms and game studios over children’s data and marketing practices, with multi‑million‑dollar settlements.
• AI and personalization. Recommendation engines that personalize content for kids based on behavior can blur into marketing. If those systems use personal information for promotional purposes, they may trigger COPPA consent requirements.
• Edtech scrutiny. Educational technology used in K–12 settings is under intense regulatory focus, especially where data is used for anything beyond providing the educational service. Marketing to students using data collected in a school context is particularly sensitive. For background on children’s privacy in education, see resources from the U.S. Department of Education.
• Global alignment. While COPPA is U.S. law, international frameworks like the UK’s Age Appropriate Design Code and the EU’s GDPR‑K are pushing companies toward higher standards for children everywhere. If your service is global, aligning your COPPA practices with these standards can reduce risk.

Drafting privacy policy templates around examples of COPPA marketing restrictions for children

If you’re building or updating privacy policy templates for children’s services, the examples of COPPA marketing restrictions for children above should translate directly into clear clauses. In practical terms, you want to:

• Describe your audience and age policies. Explain whether the service is directed to children, and how you handle users under 13 versus older users.
• Explain marketing practices in plain language. Instead of vague statements about “improving our services,” say explicitly whether you use children’s data for advertising, promotions, or cross‑promotion, and under what conditions.
• Clarify ad types. State whether you use contextual ads only, and whether you prohibit behavioral advertising to children.
• Address email, push notifications, and messaging. Spell out when you send promotional messages and how parental consent is obtained.
• Detail data sharing with third parties. Name or categorize ad networks, analytics providers, and affiliates that may receive children’s data, and explain their role.
• Highlight parental rights. COPPA gives parents the right to review, delete, and refuse further use of their child’s data. Your template should explain how parents can exercise these rights.

For a policy to be meaningful, it has to match reality. Regulators increasingly compare what companies say in their privacy policies to what their SDKs, cookies, and APIs actually do.

Practical checklist built from real examples

Instead of a legal treatise, think of COPPA as a stress test for your marketing stack. When you look at examples of COPPA marketing restrictions for children, ask yourself:

• Are any of our marketing tools tracking kids across apps or sites over time?
• Are we sending promotional messages directly to children, by email, SMS, or in‑app messaging, without a verified parent in the loop?
• Do any of our contests, giveaways, or referral programs collect friends’ contact details from children?
• Are we using children’s photos, usernames, or content in ads or promotions?
• Are our analytics and A/B tests collecting more data about kids than is reasonably necessary?

If the honest answer to any of those is “yes,” you have a COPPA problem to fix—and your privacy policy template should not try to paper it over.

For more detailed legal guidance and updated enforcement actions, you can review the FTC’s COPPA resources at FTC.gov and, for a broader children’s digital safety context, the American Academy of Pediatrics’ guidance on media use at AAP.org.

FAQ: examples of COPPA marketing restrictions for children

Q1: What are common examples of COPPA marketing restrictions for children in mobile apps?
Common examples of COPPA marketing restrictions for children in mobile apps include banning behavioral ads based on app usage, limiting analytics to basic, non‑profiling metrics, requiring parental consent before sending promotional push notifications, and disabling social sharing features that collect friends’ contact details from child users.

Q2: Can I send a newsletter to a child who signs up on my website?
Not without verifiable parental consent. COPPA allows you to respond once to a child’s request or question, but ongoing promotional newsletters count as marketing. To be compliant, you need a parent to complete a consent process and must offer an easy way to opt out later.

Q3: Is using contextual advertising always allowed under COPPA?
Contextual advertising—where ads are based only on the content being viewed, not the child’s history—is generally allowed without parental consent. However, you must ensure that any persistent identifiers used for ad delivery are not repurposed for tracking the child over time or across services.

Q4: What is an example of a COPPA violation involving social media?
An example of a COPPA issue is a child‑directed app that encourages kids to connect their accounts to a social media platform, then uses that connection to track behavior and deliver targeted ads or friend‑referral campaigns. If the app collects personal information from under‑13 users for these marketing purposes without parental consent, it risks violating COPPA.

Q5: How should a privacy policy template describe COPPA marketing limits?
A good template states clearly that children’s personal information will not be used for behavioral advertising, third‑party marketing, or ongoing promotional communications without verifiable parental consent. It should also explain any limited uses (such as contextual ads or service notifications), list categories of third‑party partners, and outline how parents can review or delete their child’s information.

Q6: Are loyalty or rewards programs for kids allowed under COPPA?
They can be, but only if they respect COPPA’s limits. You may collect the minimal information needed to run the program and must not use that data for broader profiling or third‑party marketing without parental consent. Any program that nudges kids to share friends’ contact details or social handles for rewards is especially risky.

By grounding your privacy policy templates in these examples of COPPA marketing restrictions for children, you can write documents that actually protect kids, satisfy regulators, and still give your team room to market responsibly.