Roblox does not show personalized ads to users under 18. Users under 13 see no ads related to their behavior; users aged 13-17 may see non-personalized contextual ads; only users 18 and over receive personalized advertising.
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
The clause operationalizes COPPA compliance by implementing tiered privacy settings triggered by user age, ensuring regulatory alignment while establishing conditions for service feature expansion as users age into higher-consent categories.
Interpretive note: The effectiveness of the age-gated advertising commitment depends on the reliability of Roblox's age determination process, which the policy does not fully specify, and on whether downstream ad tech vendors honor transmitted age flags.
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 →If you or your child is under 18, Roblox states it will not use your behavioral data for personalized advertising. This is a meaningful protection, though parents should note that contextual (non-personalized) ads may still be shown to users aged 13 to 17.
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"If you're under 13 years old, we'll automatically set your account to have stronger privacy settings. While in this privacy mode, some features like personalized advertising and alerts are disabled. When you turn 13, you will be able to enable additional features that are more appropriate for users ages 13 and up (though we won't personalize ads until you're 18).— Excerpt from Roblox's Roblox Privacy and Cookie Policy
REGULATORY LANDSCAPE: The advertising framework engages COPPA (FTC enforcement), which prohibits behavioral advertising to children under 13 without verifiable parental consent. For users aged 13-17, the policy's use of non-personalized contextual advertising must be evaluated against state children's privacy laws such as California's Age-Appropriate Design Code Act (AADC) and similar legislation in other states that may restrict profiling of minors for commercial purposes regardless of personalization. The FTC and state AGs are the primary enforcement authorities. GOVERNANCE EXPOSURE: Medium. The commitment to withhold personalized advertising until age 18 is stronger than the minimum required by COPPA and represents a notable consumer protection. However, the reliability of this commitment depends on the effectiveness of Roblox's age verification mechanisms; if age is self-reported without adequate verification, the tiered system may not function as described in practice. JURISDICTION FLAGS: California's AADC and the California Consumer Privacy Act impose restrictions on the use of minor data for advertising. UK Age Appropriate Design Code (Children's Code) applies to users in the UK. EU GDPR and the Digital Services Act impose additional restrictions on profiling minors. Compliance across all relevant jurisdictions requires that the age determination mechanism be sufficiently reliable. CONTRACT AND VENDOR IMPLICATIONS: Advertising technology vendors and demand-side platforms integrated with Roblox must be contractually restricted from receiving or using data attributable to users under 18 for personalized targeting. Vendor agreements should be audited to confirm these restrictions are enforceable and include audit rights and breach notification obligations. COMPLIANCE CONSIDERATIONS: The age assurance mechanism underpinning this advertising framework should be reviewed for adequacy across jurisdictions. Legal teams should confirm that contextual advertising served to 13-17 users does not involve any behavioral data signals that could constitute profiling under applicable law. Data flows to ad tech partners should be mapped to confirm that age flags are transmitted and respected downstream.
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The clause operationalizes COPPA compliance by implementing tiered privacy settings triggered by user age, ensuring regulatory alignment while establishing conditions for service feature expansion as users age into higher-consent categories.
If you or your child is under 18, Roblox states it will not use your behavioral data for personalized advertising. This is a meaningful protection, though parents should note that contextual (non-personalized) ads may still be shown to users aged 13 to 17.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.