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For users 13 and older, Roblox states it monitors, collects, uses, and stores audio captured through users' devices for voice chat enablement, safety enforcement, AI model training, and product improvement purposes.
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 that audio recordings are used for AI training and product improvement in addition to safety purposes, which engages GDPR lawful basis requirements, US state voice data statutes, and EU AI Act training data transparency obligations depending on user jurisdiction.
Interpretive note: The lawful basis asserted for AI training use of audio data is not specified per jurisdiction in the quoted language, creating interpretive uncertainty regarding GDPR compliance.
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 →This provision establishes that audio captured during Roblox sessions for users 13 and older may be retained and used to inform AI training and product improvement, in addition to voice chat and safety functions. The agreement requires compliance with applicable law for audio processing, though the specific consent mechanism or lawful basis asserted varies by jurisdiction.
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"If you use Roblox's audio features, we will monitor, collect, use, and store audio captured through your device: to enable voice chat, to make our voice-related services safer, including to detect and combat abuse and other harmful activity on our Services, in accordance with applicable law, to inform training and product improvement, and in connection with screen recordings that Creators and Users produce through the Services.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 (lawful basis) and potentially Article 9 if voice prints constitute biometric data under EU interpretation, enforced by EEA data protection authorities. In the US, Illinois BIPA may apply if voice data is used to derive biometric identifiers. The EU AI Act's requirements for disclosure of training data sources may also be implicated. The FTC's authority over unfair or deceptive practices is relevant to whether the disclosed use for AI training is adequately conspicuous. (2) GOVERNANCE EXPOSURE: High. The use of audio recordings for AI training raises purpose-limitation questions under GDPR: if users consented to or were informed of voice chat only, subsequent use for model training may require a separate lawful basis. The policy states 'in accordance with applicable law' without specifying the lawful basis asserted per jurisdiction, creating compliance uncertainty for EEA and UK operations. (3) JURISDICTION FLAGS: EEA and UK users face heightened exposure given GDPR and UK GDPR requirements for explicit disclosure of AI training use and an identifiable lawful basis. Illinois (BIPA) and Texas (CUBI) residents may have additional protections if voice data is used to generate biometric identifiers. Washington state's My Health MY Data Act may also engage depending on whether voice data intersects with health inferences. (4) CONTRACT AND VENDOR IMPLICATIONS: If Roblox shares audio data with third-party AI development vendors or model providers, data processing agreements under GDPR Article 28 would be required. Procurement teams should verify whether named service providers (e.g., AWS for hosting) receive audio data and under what contractual terms. (5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the current consent or notice mechanism for audio AI training satisfies GDPR lawful basis requirements for EEA users, whether a Data Protection Impact Assessment (DPIA) has been conducted for this processing activity, and whether applicable US state laws require additional notice or opt-out mechanisms for voice data used in AI training.
This provision establishes that audio recordings are used for AI training and product improvement in addition to safety purposes, which engages GDPR lawful basis requirements, US state voice data statutes, and EU AI Act training data transparency obligations depending on user jurisdiction.
This provision establishes that audio captured during Roblox sessions for users 13 and older may be retained and used to inform AI training and product improvement, in addition to voice chat and safety functions. The agreement requires compliance with applicable law for audio processing, though the specific consent mechanism or lawful basis asserted varies by jurisdiction.
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