CA-C-000624 Top 5% Change
Roblox — Roblox Privacy and Cookie Policy
Entity
Date detected
April 23, 2026
Effective date
April 22, 2026
Severity
High
Direction
Positive
Affected users
minors all users parents
Taxonomy
Data collection expansion
Changes
+19 sentences added · −3 sentences removed · 1 sentence modified
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What Changed

Roblox updated its Privacy and Cookie Policy on April 23, 2026 to add detailed language explaining how it collects 'persistent identifiers' (like IP addresses and device IDs) from children who sign up for the platform, and what those identifiers are used for. The policy now specifically lists permitted uses for children's data, such as maintaining the platform, serving contextual ads, and ensuring security, and states that Roblox takes measures to prevent those identifiers from being used for other purposes. The previous version included a summary of recent changes and some language about advertising and authority disclosures, which have been removed as the new policy takes effect.

Consumer Impact (what this means for users)

Roblox has added explicit disclosures about collecting persistent identifiers — like IP addresses and device IDs — from children, and has listed the specific purposes for which that data can be used. This is a meaningful transparency improvement for parents, as it clarifies what data is gathered from minors and limits its use to defined internal operations. You can review the full updated policy on Roblox's website to understand exactly what data is collected from your child and the stated limits on its use.

Obligation Changes (what shifted)

3
New obligations
1
Protection removed
Consumers Added

Parents are now told exactly what tracking data Roblox collects from their children and what it's allowed to be used for.

Vendors Added

Third-party service providers helping Roblox run its platform are explicitly acknowledged as having access to children's tracking data.

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Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
CFAA
United States Federal
CAN-SPAM
United States Federal
DMCA
United States Federal
DSA
European Union
GDPR
European Union
UK GDPR
United Kingdom

Why It Matters (compliance & risk perspective)

Roblox's platform is heavily used by children, and this update is one of the most detailed disclosures the company has made about what tracking data it collects from minors and how it is used. However, the simultaneous removal of advertising and authority-sharing disclosures without confirmed replacement raises legitimate questions about whether Roblox's transparency has improved or shifted.

📈 Historical Context

ConductAtlas has recorded 2 material changes to this document (since April 2026). An additional minor or cosmetic changes were excluded.

Across all monitored documents, Roblox has made 4 significant changes.

2 of Roblox's significant changes have been classified as negative for consumers.

Key Clauses Affected

Persistent Identifier Collection from Children

Roblox now explicitly discloses that it collects persistent identifiers (IP addresses, device IDs) from child users and limits their use to six defined internal operations.

Service Provider Disclosure for Children's Data

Roblox has added language disclosing that third-party service providers support the internal operations involving children's persistent identifier data.

Removal of Advertising Disclosure Summary

Prior language clarifying who can see personalized vs. non-personalized ads on Roblox has been removed from the policy changelog without confirmed replacement.

Full clause-by-clause analysis available with Watcher.

Evidence Verification

✓ Verified
Previous Version
875136878508ad3f44fee9e4efc73805791339066ceb2437f32b2445d3320750
April 22, 2026 06:03 UTC
✓ Verified
Current Version
ee8d96b7f6d3f041e67809b13f4ec5bfcaaa2e61096eb76f3ef1d033541d5933
April 23, 2026 06:06 UTC
✓ Verified
Change Detected
April 23, 2026 06:06 UTC
How to Cite
ConductAtlas Policy Archive
Entity: Roblox | Document: Roblox Privacy and Cookie Policy | Record: CA-C-000624
Captured: 2026-04-23 06:06:34 UTC
URL: https://conductatlas.com/change/2026-04-23-roblox-roblox-privacy-and-cookie-policy-624/
Accessed: May 2, 2026

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Institutional Analysis (Compliance & legal intelligence)

Assessment

Roblox has added six new sentences explicitly addressing persistent identifier collection from children, limiting use to defined internal operations (platform maintenance, authentication, contextual advertising, security, compliance), and disclosing reliance on service providers for those operations. This directly touches COPPA (16 CFR Part 312), which requires operators to disclose what personal information is collected from children and how it is used. The removal of the 'summary of recent changes' section, including prior language on advertising and authority disclosures, warrants a quick check to confirm no material commitments were silently dropped. Action required: compliance teams with child-user exposure should confirm their own disclosures and DPAs align with Roblox's updated children's data practices.

Regulatory Exposure

1. COPPA (Children's Online Privacy Protection Act), 16 CFR §31

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Compliance intelligence locked

Obligation analysis, escalation trigger, board language, and recommended action.

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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-000624.

Full Changes

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Document Context

Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Captured
April 23, 2026
Source URL
https://en.help.roblox.com/hc/en-us/articles/115004630823-Roblox-Privacy-and-Cookie-Policy
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