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 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 →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.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
window.GLOBAL_SN_OEST.init({ ssrOest: "OUVCMDQyfDE3Nzg1MjI0NDc5OTN8QzJfQTIyRF9GMjU0X0RCRTlfQjMwQkU2OTVCNThC", shouldSetCC: true, useCC:true, i18nKey: "Curve + Plus" }); ... key:updateOest ... fetch(r,{method:"POST",headers:i}).then
Monitoring
Roblox has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"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 Roblox 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 a private right of action with statutory damages of $1,000 to $5,000 per violation. Texas CUBI and Washington's My Health MY Data Act impose similar but distinct obligations. GDPR treats biometric data as a special category requiring explicit consent under Article 9. (2) GOVERNANCE EXPOSURE: High. BIPA has generated substantial class action litigation against technology companies; the policy's disclosure that biometric data may be collected without specifying the features or jurisdictions involved creates uncertainty about the scope of consent mechanisms in place. The private right of action under BIPA means this provision creates direct litigation exposure in addition to regulatory risk. (3) JURISDICTION FLAGS: Illinois BIPA creates the highest exposure due to its private right of action and broad definition of biometric identifiers. Texas CUBI applies to Texas residents. Washington My Health MY Data Act may apply depending on the nature of the data. GDPR Article 9 applies to EU/EEA users and requires explicit consent for biometric processing. (4) CONTRACT AND VENDOR IMPLICATIONS: If biometric data collection is implemented through third-party SDKs or service providers, vendor agreements must include BIPA-compliant data handling terms; procurement teams should assess whether any third-party facial recognition or avatar creation vendors are subject to BIPA obligations and whether liability is appropriately allocated. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should identify all platform features that involve biometric data collection; verify that jurisdiction-specific consent flows are implemented for Illinois and other applicable states; ensure a publicly available biometric data retention and destruction schedule exists as required by BIPA; and assess whether existing consent mechanisms satisfy BIPA's written consent standard.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
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 3 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.