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> "They should have simply said "No children under 13" and made a date of birth selector making it impossible to select a date younger than 13."

I don't believe the FTC would consider this compliance, since such a dialogue is designed to encourage children to lie.

>3. Can I block children under 13 from my general audience website or online service?

> Yes. COPPA does not require you to permit children under age 13 to participate in your general audience website or online service, and you may block children from participating if you so choose. By contrast, you may not block children from participating in a website or online service that is directed to children as defined by the Rule. See FAQ D.2 above.

> If you choose to block children under 13 on your general audience site or service, you should take care to design your age screen in a manner that does not encourage children to falsify their ages to gain access to your site or service. Ask age information in a neutral manner at the point at which you invite visitors to provide personal information or to create a user ID.

A bit more to the point:

> In designing a neutral age-screening mechanism, you should consider: Making sure the data entry point allows users to enter their age accurately. An example of a neutral age-screen would be a system that allows a user freely to enter month, day, and year of birth. A site that includes a drop-down menu that only permits users to enter birth years making them 13 or older, would not be considered a neutral age-screening mechanism since children cannot enter their correct ages on that site.

https://www.ftc.gov/tips-advice/business-center/guidance/com...




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