Operator (COPPA Definition)

Under COPPA, an operator is any person or entity that operates a website or online service directed to children, or has actual knowledge that it is collecting personal information from children. This definition is broader than just website owners—it includes anyone who collects or maintains personal information through a website or online service. The FTC has clarified that operators include app developers, plugin providers, advertising networks, and even social media platforms that are accessible to children. An entity can be an operator even if it doesn't directly run a website, as long as it collects information through that site. For instance, an analytics company embedded in a children's app is considered an operator for COPPA purposes. This classification matters because operators have direct compliance obligations including obtaining verifiable parental consent, providing clear privacy notices, implementing reasonable data security, and limiting data collection. Multiple parties can be operators for the same service—both the app developer and any third-party services collecting data through the app. Joint operators can allocate responsibilities through contracts, but each remains potentially liable for COPPA compliance.