The policy states that Roblox will not collect additional personal information from users under 13 beyond what is required for account setup and protection, and will delete any excess personal information received, cancel the account, or apply age-appropriate protections.
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 operationalizes COPPA's data minimization requirement for child users and establishes three specific remedial actions Roblox states it will take upon receiving excess personal information from under-13 users. The provision also reflects the policy's stated commitment to filtering public communications from child users to remove personal information.
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 →Under this provision, users under 13 are subject to data minimization controls, and the agreement states that personal information submitted beyond the required minimum will be deleted, the account cancelled, or age-appropriate restrictions applied. Parents and guardians may request review, deletion, or modification of a child's personal information through the Customer Support Form.
How other platforms handle this
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...
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
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"If you're under 13 years old, we will only ask you to tell us the information we need to set up or protect your account. If you give us more of your Personal Information, we will: delete any additional Personal Information we've collected from you (unless the law requires us to keep it), cancel your account, or turn on age-appropriate protections on your account.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: This provision directly implements COPPA's data minimization and parental consent requirements, enforced by the FTC. COPPA (15 U.S.C. 6501 et seq. and 16 CFR Part 312) prohibits collection of personal information from children under 13 beyond what is reasonably necessary for participation in the online activity. The FTC has authority to seek civil penalties for violations. 2. GOVERNANCE EXPOSURE: Medium. The provision's stated data minimization practice is consistent with COPPA requirements, but the adequacy of technical controls to enforce it (including automated filtering of public communications) is operationally significant and subject to regulatory scrutiny. The policy acknowledges that filtering systems are not 100% effective. 3. JURISDICTION FLAGS: US federal COPPA applies nationally. State attorneys general in all 50 states have concurrent enforcement authority under COPPA. International equivalents include GDPR Article 8 for EU child users and the UK Children's Code. 4. CONTRACT AND VENDOR IMPLICATIONS: Service providers processing personal information from under-13 users on behalf of Roblox are subject to the policy's stated contractual requirements and measures to protect security, confidentiality, and integrity. Vendor contracts should be reviewed to confirm COPPA-compliant data processing restrictions. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit technical filtering controls for public communications to assess their effectiveness in preventing collection of personal information from child users, and confirm that parental request mechanisms for data review and deletion are operationally functional and responsive within COPPA's required timeframes.
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This provision operationalizes COPPA's data minimization requirement for child users and establishes three specific remedial actions Roblox states it will take upon receiving excess personal information from under-13 users. The provision also reflects the policy's stated commitment to filtering public communications from child users to remove personal information.
Under this provision, users under 13 are subject to data minimization controls, and the agreement states that personal information submitted beyond the required minimum will be deleted, the account cancelled, or age-appropriate restrictions applied. Parents and guardians may request review, deletion, or modification of a child's personal information through the Customer Support Form.
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