Roblox states that in some locations and for certain features it may collect biometric data such as facial geometry, and says it will seek consent where required by law before doing so.
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
Biometric data is subject to strict state-level laws in the US (notably Illinois BIPA) that require informed written consent, impose retention and destruction obligations, and provide a private right of action; the policy does not specify which features or jurisdictions are involved.
Interpretive note: The policy does not specify which platform features or jurisdictions are subject to biometric data collection, making the operational scope of this provision ambiguous.
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 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 →Shifted from general biometric collection framework to specific age assurance use case with explicit deletion guarantee post-assessment and reference to separate facial media policy.
View full change record →This addition discloses new biometric data collection practices (facial geometry) and represents a significant expansion of personal data types Roblox collects from users.
View full change record →Users in jurisdictions with biometric privacy laws, particularly Illinois, may have rights to consent, access, and deletion of biometric data collected by Roblox; the policy does not specify which platform features involve biometric collection, creating ambiguity about the scope of this provision.
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"In certain jurisdictions and for certain features, we may collect biometric identifiers or biometric information, such as facial geometry, in connection with specific features on our platform. Where required by applicable law, we will obtain your consent prior to collecting such information and will provide you with additional notices about our data practices for such information.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: This provision engages the Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14), which requires informed written consent before collecting biometric identifiers, mandates a publicly available retention and destruction schedule, and provides …
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Biometric data is subject to strict state-level laws in the US (notably Illinois BIPA) that require informed written consent, impose retention and destruction obligations, and provide a private right of action; the policy does not specify which features or jurisdictions are involved.
Users in jurisdictions with biometric privacy laws, particularly Illinois, may have rights to consent, access, and deletion of biometric data collected by Roblox; the policy does not specify which platform features involve biometric collection, creating ambiguity about the scope of this provision.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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