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Roblox states it shares each user's username, display name, user ID, game metrics, UGC transaction details, and IP-derived regional location with the creators of experiences the user interacts with.
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 establishes that experience creators receive identifiable user data including transaction details and location-derived information without a separate consent action by users at the point of entering an experience, which may engage GDPR transparency and data sharing obligations depending on whether creators qualify as independent data controllers.
Interpretive note: The policy does not specify whether experience creators are classified as data processors or independent data controllers under GDPR, which determines the applicable compliance framework and affects interpretation of data sharing obligations.
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 these terms, each time a user interacts with a Roblox experience, the experience creator receives the user's username, display name, user ID, game metrics, UGC transaction details, and a regional location derived from the user's IP address. The policy states that raw IP addresses are not shared with creators.
Cross-platform context
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"The creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators. We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: Sharing identifiable user data including transaction details and location with third-party creators engages GDPR Article 13 (transparency at point of collection) and Article 26 (joint controller arrangements) if creators exercise independent control over user data. The FTC Act applies to the adequacy and accuracy of disclosures about third-party data sharing. CCPA/CPRA requires disclosure of categories of third parties with whom personal data is shared. (2) GOVERNANCE EXPOSURE: Medium. The policy discloses this sharing but does not specify whether experience creators are classified as data processors (under Roblox's instruction) or independent data controllers, which determines the applicable GDPR compliance framework. If creators are independent controllers, GDPR Article 26 joint controller agreements may be required and creators' own privacy policies would need to meet GDPR standards. (3) JURISDICTION FLAGS: EEA and UK users face heightened exposure if creators lack GDPR-compliant data handling practices. The policy states that Creator Event activity is subject to the third-party platform's privacy policy, but the general creator data sharing arrangement does not carry this caveat, creating potential gaps in user notice. (4) CONTRACT AND VENDOR IMPLICATIONS: Roblox's developer agreements with creators should specify the permissible uses of shared user data and prohibit secondary use or onward transfer. Compliance teams should review whether Roblox's developer terms include adequate data processing or controller-level obligations for creators receiving user data. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the current GDPR transparency disclosure for creator data sharing is sufficient at the point of user interaction with each experience, and whether the policy's disclosure of UGC transaction detail sharing satisfies CCPA categories of third-party sharing requirements.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes that experience creators receive identifiable user data including transaction details and location-derived information without a separate consent action by users at the point of entering an experience, which may engage GDPR transparency and data sharing obligations depending on whether creators qualify as independent data controllers.
Under these terms, each time a user interacts with a Roblox experience, the experience creator receives the user's username, display name, user ID, game metrics, UGC transaction details, and a regional location derived from the user's IP address. The policy states that raw IP addresses are not shared with creators.
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