On April 19, 2026, Roblox updated the introduction and table of contents of their Privacy and Cookie Policy, replacing a simple header with a detailed navigational structure that outlines all major sections of the policy. The document now prominently welcomes users and asks whether they are under 13 or responsible for an under-13-year-old, and it displays a comprehensive table of contents covering data collection, sharing, security, and regional rights. This structural change makes the policy easier to navigate and signals that Roblox is reorganizing how it presents its privacy practices ahead of a broader update effective April 30, 2026.
Roblox is signaling a major privacy policy overhaul effective April 30, 2026, with explicit new sections on children's data, regional rights, and data sharing. Parents and users — especially those in the EU, UK, Brazil, or South Korea — should review the full updated policy when it goes live.
Roblox has restructured the opening of its privacy policy to include a detailed table of contents and a direct prompt addressing users under 13 and their parents or guardians. This makes it easier for users — especially families — to find relevant sections about data collection, sharing, and regional rights. The substantive policy content has not changed yet, but a broader update is scheduled for April 30, 2026.
Roblox restructured the header and added a full table of contents to its Privacy and Cookie Policy on April 19, 2026, with a new prominent callout for users under 13. This is primarily a navigational and structural change rather than a substantive policy revision. However, the explicit 'Are you Under 13' prompt and expanded section headings touching COPPA, GDPR (EEA/UK/Switzerland), LGPD (Brazil), and Korean data law signal that the forthcoming April 30, 2026 update will carry substantive compliance obligations. Compliance teams should treat this as a preparatory signal and begin reviewing the April 30 update now.
The structural additions reference jurisdiction-specific sections implicating: (1) COPPA (15 U.S.C. §§ 6501–6506) — the 'Under 13' callout and 'Personal Information of Children and Parental Consent' heading directly invoke COPPA requirements for verifiable parental consent and data minimization for child users; (2) GDPR Arts. 5, 12, 13, 14, and 17 — the EEA/UK/Switzerland section headings reference Automated Decision-Making (Art. 22), Data Subject rights (Arts. 15–21), Legal Disclosure, and international transfer (Arts. 44–49 via SCCs); (3) UK GDPR and ICO guidance on children's data (Age Appropriate Design Code / Children's Code); (4) LGPD (Brazil) Art. 14 — children and adolescent data; and (5) South Korea PIPA (Personal Information Protection Act) — the Republic of Korea-specific section. The FTC retains primary COPPA enforcement jurisdiction in the US. The EDPB and national DPAs govern EEA obligations. The ICO governs UK obligations.
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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000515.
ConductAtlas Policy Archive Entity: Roblox | Document: Roblox Privacy and Cookie Policy | Record: CA-C-000515 Captured: 2026-04-19 06:04:31 UTC URL: https://conductatlas.com/change/2026-04-19-roblox-roblox-privacy-and-cookie-policy-515/ Accessed: April 21, 2026
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