Roblox may use content you and other users have posted — including chat and audio — to train or improve its AI/ML content filtering systems, where permitted by law.
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 establishes a permitted use category for user-generated content beyond the primary service delivery function, expanding the operational scope of data processing activities the platform may conduct. This authorization operates independently of content removal or moderation decisions.
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 →The complete removal of AI/ML training disclosure represents a significant gap in transparency about whether user-generated content is used for model training purposes.
View full change record →User-generated content including chat messages and audio recordings may be repurposed for AI model training, raising concerns about ongoing data use beyond its original purpose. This applies to all users, including potentially minors.
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"Where the law allows us to, we may use the content you and other users have posted for training or to help us to improve the way we filter content on our platform.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
The use of user content for ML training constitutes secondary processing under GDPR Article 5(1)(b) and may require a compatible purpose assessment or fresh consent. Under CCPA/CPRA, this may qualify as a new use requiring updated disclosures. Risk teams should assess whether adequate consent or legitimate interest justification exists, particularly for content generated by minor users.
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The clause establishes a permitted use category for user-generated content beyond the primary service delivery function, expanding the operational scope of data processing activities the platform may conduct. This authorization operates independently of content removal or moderation decisions.
User-generated content including chat messages and audio recordings may be repurposed for AI model training, raising concerns about ongoing data use beyond its original purpose. This applies to all users, including potentially minors.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.