Loyalty Register glossary

Age restriction

A rule in a loyalty program's terms that sets a minimum age to join, or limits what younger members can earn, receive or redeem.

An age restriction, or loyalty program age requirement, is a rule in a program’s terms that sets a minimum age to join, or limits what younger members can do, such as earning on certain products, receiving marketing or redeeming some rewards. Most programs set a minimum age and treat it as both a legal safeguard and a product decision.

Understanding the termAll terms

Why do loyalty programs set a minimum age?

The main reason is privacy law. In the US, the FTC’s COPPA Rule applies to online services directed to children under 13, and to general audience services that know they are collecting personal information from children under 13; covered operators must notify parents and obtain verifiable parental consent before collecting it. Under the California Consumer Privacy Act, a business can sell the personal information of a child it knows to be under 16 only with opt-in consent, which must come from a parent for children under 13. In the EU, the age below which parental consent is needed for online services is set by each member state, between 13 and 16. A program that collects purchase history and sends personalized offers falls squarely within these rules.

Are there other reasons?

Yes. Products with legal age limits, such as alcohol or tobacco, need age checks before members can earn on them or redeem rewards linked to them. Contracts with minors can be harder to enforce, which matters for terms that govern points and accounts. And some rewards, such as travel or financial products, are simply not suitable for younger members.

How do programs apply age rules?

Most ask for a date of birth at enrollment and refuse or limit accounts below the minimum. Some set the minimum at 13, others at 16 or 18, depending on their markets and products. Others allow younger members with a parent’s involvement: Starbucks Rewards terms say the program is not intended for anyone under 13, and that members between 13 and 18 may take part only under the supervision of a parent or legal guardian who agrees to the terms. Airline programs often let a parent open an account for a child so the child earns miles on family trips. Wherever the line is drawn, it should be the same in the terms, the enrollment form and the systems that send offers.

What should you watch?

Ask only for the age data you need, and use it: a birthday field collected for a birthday reward also tells you who is under the minimum age. Decide what happens when a member reaches the minimum, and what happens to points if an underage account is found. Check the rules in every market you operate in, since thresholds differ, and review them with counsel when you add products that carry age limits.