Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Cookie and Tracking Technology Use

Medium severity Medium confidence Inferredfromcontext Uncommon · 27 of 343 platforms
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Recent governance activity Roblox recorded 3 documented changes in the last 30 days.
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Document Record

What it is

The policy is titled the Roblox Privacy and Cookie Policy and addresses cookie and tracking technology practices as part of the overall data collection framework. The document references a separate cookie policy framework applicable to Roblox's websites and services.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The policy's combined privacy and cookie governance structure means that cookie consent mechanisms, opt-out rights, and tracking technology disclosures are addressed within a single document, which has operational implications for compliance with GDPR's ePrivacy Directive requirements and US state opt-out rights for targeted advertising using cookies and similar technologies.

Interpretive note: The provided document excerpt does not include the full cookie policy provisions; assessment of specific cookie consent mechanisms and opt-out procedures is based on the document's combined title and general privacy framework rather than specific cookie provision text.

Recent Activity

This document changed recently

Medium May 1, 2026

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 →
Medium Apr 23, 2026

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 →
Medium Mar 8, 2026

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 →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 3, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Change history

removed Jun 24, 2026

Removal of detailed tracking technology disclosure aligns with restrictions on such tracking for minors under age-tiered policy, though the current version mistakenly lists a contact provision under this name.

View full change record →
modified May 14, 2026

Previous version had no excerpt; current version now includes specific enumeration of tracking technologies (pixel tags, local storage, SDKs), their purposes, and user control limitations.

View full change record →

Consumer impact (what this means for users)

The agreement governs both personal data and cookie or tracking technology practices across Roblox's services, including websites and applications. Users in the EU/EEA may have rights to consent to or refuse non-essential cookies under applicable ePrivacy frameworks.

How other platforms handle this

Ledger Medium

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.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Strava Medium

We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
To reach us with questions or requests regarding your Personal Information, our information about how to contact us is included below.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: Cookie and tracking technology practices engage the EU ePrivacy Directive (2002/58/EC as amended), national implementing legislation, and GDPR consent requirements for non-essential cookies. In the US, California's CPRA opt-out rights for sharing personal information via tracking technologies (including cross-context behavioral advertising) are relevant. The FTC Act's unfairness and deception standards apply to cookie-related disclosures. 2. GOVERNANCE EXPOSURE: Medium. The combination of privacy and cookie governance in a single document is common practice, but requires that cookie consent mechanisms and opt-out rights be operationally implemented across all service surfaces including mobile apps and console platforms, where consent UI standards differ from web browsers. 3. JURISDICTION FLAGS: EU/EEA jurisdictions require prior consent for non-essential cookies under national ePrivacy laws. UK ICO guidance similarly requires opt-in consent for non-essential cookies. California CPRA requires a clear opt-out for sharing personal information through tracking technologies used for cross-context behavioral advertising. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising and analytics vendors placing cookies or similar tracking technologies on Roblox's services must operate within disclosed consent frameworks and applicable regulatory requirements. Vendor data processing agreements should address cookie data processing and retention obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit cookie consent banners and preference management tools across all service surfaces to confirm they reflect the policy's stated practices and meet applicable jurisdictional consent standards. The policy's age-tiered advertising restrictions should be enforced at the cookie and tracking technology level to prevent personalized ad delivery to under-18 users.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over cookie-related data practices and cross-context behavioral advertising disclosures under its unfair and deceptive practices authority.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-000602
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
163e270135d4554ade90ad7320f2517870809ebb96b4cd9ae9cd9697501032fa
Analysis generated
May 20, 2026 20:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-000602
Captured: 2026-05-20 20:33:57 UTC
SHA-256: 163e270135d4554a…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/cookie-and-tracking-technology-use/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Roblox's Cookie and Tracking Technology Use clause do?

The policy's combined privacy and cookie governance structure means that cookie consent mechanisms, opt-out rights, and tracking technology disclosures are addressed within a single document, which has operational implications for compliance with GDPR's ePrivacy Directive requirements and US state opt-out rights for targeted advertising using cookies and similar technologies.

How does this clause affect you?

The agreement governs both personal data and cookie or tracking technology practices across Roblox's services, including websites and applications. Users in the EU/EEA may have rights to consent to or refuse non-essential cookies under applicable ePrivacy frameworks.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 27 platforms. See the full comparison.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.