[rmrm]

knowing the childs email address in and of itself appears to be data collection in regards to COPPA.

http://business.ftc.gov/documents/bus45-how-comply-childrens...

[bmj]

Which means it would be impossible to provide an email service to a child, right, short of self-hosting?

[rmrm]

I don't think so, its just that you'd have to obtain parental consent 100% of the time. Data gathering is baked into providing an email service, that part of COPPA seems logical enough to me. The issue of targeted ads vs untargeted ads vs no ads doesn't appear to have anything to do with anything, other than what you'd notify the parents you are doing, and what you are asking their consent of.