COPPA, the federal children’s privacy rule the FTC enforces, applies to websites and online services directed to children under 13, and to any site that knows it is collecting personal information from a child that young. A center’s website written for parents, with a tour form a parent fills in, is not directed to children. The rule comes into play in the pieces programs tend to add later: a student login at a tutoring center, learning games on the site, a classroom app, online sessions where children under 13 sign in.
Two details matter for marketing.
Tracking counts as collection. Under COPPA, personal information includes persistent identifiers such as a cookie number or an IP address. An ad pixel or an analytics tag on a page built for children collects personal information even if nobody types a name.
Advertising needs the parent to opt in. The FTC finalized changes to the rule on January 16, 2025, and its own guidance dates the amended rule April 22, 2025. Operators now need separate verifiable parental consent before they disclose a child’s personal information to third parties for targeted advertising.
Whether a page counts as directed to children is a judgment the FTC makes from the subject matter, the visual and audio content, animated characters and other child-oriented activities. A cheerful parent page is fine. A games corner with cartoon characters and a sign-in box is a different question.
How we set it up for a program:
- Parent-facing pages, tour forms and ads carry ordinary measurement, and parent inquiries go into the CRM like any other lead.
- Student portals, learning games and online tutoring rooms carry no ad pixels and no remarketing tags. If they need analytics, the portal’s provider and your consent process decide what is allowed, not the ad platform.
- Audiences are parents and the area around your site. Nothing is aimed at children.
- Children’s photos and names stay out of ads, profiles and posts unless a parent has given written permission under your own policy, and we plan every campaign so it works without them.
None of this stops a program from advertising. It decides where the tracking goes.