Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Age-Gated Advertising Framework

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Recent governance activity Roblox recorded 18 documented changes in the last 30 days.
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This three-tier advertising structure is directly relevant to parents and regulators because it determines what behavioral data is used for commercial purposes at each age threshold, and affects whether Roblox's ad practices comply with COPPA, the FTC's guidance on children's advertising, and emerging state children's online privacy laws.

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.

Recent Activity

This document changed recently

Medium May 1, 2026

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…

Medium Apr 23, 2026

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 includin…

Medium Mar 8, 2026

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…

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    If you believe your child's account is incorrectly categorized by age, submit a correction request through the Roblox Customer Support Form at roblox.com/support to ensure the correct advertising settings apply.

How other platforms handle this

Groq Medium

There is certain information that we collect automatically from your use of our online Services and from your device(s) used to access those Services, for example by using the types of technologies discussed in the 'Online Analytics' section below. This information includes your IP address, page vie...

Egnyte Medium

We use cookies, web beacons, and other tracking technologies to collect information about your browsing activities on our website. We may use third-party analytics providers such as Google Analytics to help us understand how users interact with our website. We may also work with third-party advertis...

Shopify Medium

We share information with third parties who help us operate our business, including to assist us with marketing campaigns, advertising, analytics and research. These service providers are given access to your information as reasonably necessary to perform these tasks on our behalf and are obligated ...

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and has issued guidance on behavioral advertising to children, making it the primary federal authority for evaluating the advertising framework's compliance.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009288
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c6407ec7af45f80666fa8f24770b6c2c70801d3e6e370d2c57ff91c080cdfd3e
Analysis generated
May 10, 2026 16:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-009288
Captured: 2026-05-10 16:48:27 UTC
SHA-256: c6407ec7af45f806…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/age-gated-advertising-framework/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Roblox's Age-Gated Advertising Framework clause do?

This three-tier advertising structure is directly relevant to parents and regulators because it determines what behavioral data is used for commercial purposes at each age threshold, and affects whether Roblox's ad practices comply with COPPA, the FTC's guidance on children's advertising, and emerging state children's online privacy laws.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.