Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
Roblox states it processes user Personal Information to determine ad display; personalized ads are shown only to users 18 and older (with consent where required by applicable law), while users under 18 receive only non-personalized ads.
This analysis describes what Roblox's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a categorical age threshold of 18 for personalized advertising (rather than the lower threshold of 13 common in many platforms), and requires consent for personalized ads where applicable law mandates it, engaging GDPR consent requirements for EEA users and FTC guidelines for advertising to minors.
Interpretive note: The policy states consent is required 'where required' for personalized ads but does not specify the consent mechanism or lawful basis asserted in jurisdictions where consent is not mandated, creating interpretive uncertainty about the operational implementation.
The updated policy restricts personalized advertising based on age. Users under 18 will see only nonpersonalized ads on the platform, while users 18 and older may see personalized ads if they provide consent where required. The revised language also removes the previous statement that the platform collects personal information from under-13 accounts for advertising purposes, clarifying that such data is not used for marketing. Users 18 or older can control whether they see personalized ads through Roblox account settings.
View change record →The updated policy adds explicit language disclosing that Roblox collects persistent identifiers (IP addresses and unique device identifiers) from all users, including children, for purposes including account authentication, ad frequency capping, network communications, and security. The policy states Roblox implements technical, contractual, and other measures to ensure these identifiers are not used for purposes outside the listed scope. This represents a clarification and formalization of practices rather than a change to what data is collected, but it does establish contractual limits on how that data may be used. You can review the full updated Privacy Policy to understand which persistent identifiers are collected and the specific operational purposes for which they are retained.
View change record →The updated policy clarifies that parent email addresses constitute the only personal information collected from child accounts under COPPA, rather than listing persistent identifiers. The policy now states that personalized ads are not enabled until age 18, rather than leaving this ambiguous when a child turns 13. These clarifications affect how parents and children understand what data Roblox collects and when advertising becomes personalized; however, the underlying data practices do not appear to have changed operationally. The policy removed detailed descriptions of collection purposes (such as internal operations), which means parents now have less granular explanation of data uses, though stated practices remain.
View change record →Under these terms, users under 18 will see non-personalized ads regardless of account settings, and users 18 and older may control personalized ad preferences through Roblox account settings. The policy states that consent is required for personalized ads where applicable law mandates it, which applies to EEA and UK users under GDPR.
Cross-platform context
See how other platforms handle Advertising: Personalized Ads at Age 18, Non-Personalized Ads for Under-18 Users and similar clauses.
Compare across platforms →Monitoring
Roblox has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.
"We process your Personal Information to display ads on Roblox. Specifically, we use information we collect to decide which ads to show you on Roblox. Roblox also may work with partners to directly show you ads on Roblox. Users under 18 years old will see only nonpersonalized ads. Users 18 years old and older will see personalized ads on Roblox (with consent, where required). If you are 18 or older, you can control whether you see personalized ads through your Roblox settings.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: Personalized advertising using Personal Information engages GDPR Article 6 (consent as lawful basis for EEA/UK users) and the ePrivacy Directive for cookie-based ad targeting. The FTC Act applies to advertising practices directed at or reaching minors. COPPA prohibits behavioral advertising targeting users under 13. The policy's 18+ threshold for personalized ads represents a more restrictive standard than COPPA's 13-year threshold. (2) GOVERNANCE EXPOSURE: Medium. The policy states personalized ads are shown to 18+ users 'with consent, where required,' but does not specify the consent mechanism or lawful basis for jurisdictions where consent is not the required basis (e.g., whether legitimate interests is asserted for any ad personalization). Compliance teams should verify that consent collection for personalized ads is operationally implemented for EEA/UK users and meets GDPR consent standards (freely given, specific, informed, unambiguous). (3) JURISDICTION FLAGS: EEA and UK users require valid GDPR consent for personalized advertising based on cookie or behavioral data. California residents have CCPA/CPRA opt-out rights for sale or sharing of personal data for cross-context behavioral advertising. The policy's disclosures about advertising partners and data sharing for advertising purposes engage California's 'Do Not Sell or Share' requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: The policy states Roblox may work with partners to directly show ads, implying third-party ad serving on the platform. These arrangements require data processing agreements and, for EEA users, may require consent management platform integration. Developers advertising on Roblox are required to provide business, financial, and tax information, which should be addressed in advertiser terms. (5) COMPLIANCE CONSIDERATIONS: Legal teams should verify whether the opt-out mechanism for personalized ads available to 18+ users in Roblox settings constitutes a valid CCPA 'Do Not Sell or Share' opt-out, and whether the non-personalized ad serving to under-18 users is technically implemented to exclude behavioral data from ad selection.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes a categorical age threshold of 18 for personalized advertising (rather than the lower threshold of 13 common in many platforms), and requires consent for personalized ads where applicable law mandates it, engaging GDPR consent requirements for EEA users and FTC guidelines for advertising to minors.
Under these terms, users under 18 will see non-personalized ads regardless of account settings, and users 18 and older may control personalized ad preferences through Roblox account settings. The policy states that consent is required for personalized ads where applicable law mandates it, which applies to EEA and UK users under GDPR.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.