The policy establishes a three-tier advertising structure: users under 13 receive no personalized advertising; users aged 13-17 may receive some additional features but not personalized ads; personalized advertising is not enabled until age 18.
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 age-gated advertising eligibility thresholds that govern how the platform serves advertisements across its user base, creating distinct operational obligations for ad delivery systems and age verification processes. The provision's restriction of personalized advertising to users 18 and older sets a higher threshold than COPPA's 13-year floor and interacts with both COPPA and emerging state children's digital privacy laws.
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 this provision, users under 13 have personalized advertising and certain alert features automatically disabled, and users under 18 are not eligible for personalized ads under the policy's stated terms. The agreement states that stronger privacy settings are applied automatically based on age at account creation.
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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
1. REGULATORY LANDSCAPE: This provision directly engages COPPA (16 CFR Part 312), enforced by the FTC, which restricts behavioral advertising to users under 13. The policy's extension of the personalized ads restriction to under-18 users also interacts with California's Age-Appropriate Design Code (AB 2273), which requires default privacy settings for users under 18. EU supervisory authorities may also evaluate this provision under GDPR Article 8 regarding consent conditions for children's data. 2. GOVERNANCE EXPOSURE: High. The platform serves a large population of minor users globally, and the adequacy of technical age verification controls to enforce these advertising restrictions is subject to ongoing regulatory scrutiny. Failure to enforce the stated age-tiered restrictions could constitute a COPPA violation subject to FTC enforcement, with civil penalties available per violation. 3. JURISDICTION FLAGS: Heightened exposure exists in the United States under COPPA and state children's privacy laws (California, Texas, Florida); in the EU/EEA under GDPR Article 8 and national implementing legislation; and in the UK under the Age Appropriate Design Code (UK Children's Code). The provision's self-imposed restriction to age 18 for personalized ads may create compliance dependencies in jurisdictions where the majority age differs. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising partners and data management platform vendors operating in the Roblox ecosystem should review contractual representations regarding user age and advertising eligibility. The policy's stated restrictions on serving personalized ads to under-18 users create downstream contractual obligations for third-party ad technology vendors that may require audit rights and compliance certifications. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether age assurance technical controls are sufficient to reliably enforce the stated advertising restrictions, and whether advertising partner contracts reflect the under-18 personalized ad prohibition. Data flow mapping should confirm that user age signals are propagated to all ad serving systems.
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This provision establishes age-gated advertising eligibility thresholds that govern how the platform serves advertisements across its user base, creating distinct operational obligations for ad delivery systems and age verification processes. The provision's restriction of personalized advertising to users 18 and older sets a higher threshold than COPPA's 13-year floor and interacts with both COPPA and emerging state children's digital privacy …
Under this provision, users under 13 have personalized advertising and certain alert features automatically disabled, and users under 18 are not eligible for personalized ads under the policy's stated terms. The agreement states that stronger privacy settings are applied automatically based on age at account creation.
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