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.
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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 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.
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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.
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