The policy states that Roblox limits data retention to what is reasonably necessary for specified purposes and employs access controls, purpose-based tagging, employee training, and data segregation to manage data. Persistent identifiers may be retained for safety and security purposes for up to two years following account deletion.
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 a stated retention framework and specifies a two-year post-deletion retention window for persistent identifiers for safety and security purposes. The two-year post-deletion retention period is an operationally significant disclosure for users who delete their accounts, as identifiers including IP addresses and device identifiers may continue to be processed during that period.
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, account deletion initiates permanent deletion of personal data in Roblox's systems, but persistent identifiers such as IP addresses and device identifiers may be retained and processed for safety and security purposes for up to two years after deletion. The agreement also states that data may be retained longer if required for legal or regulatory compliance.
How other platforms handle this
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.
We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.
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"Roblox maintains a retention policy designed to limit data retention to what is reasonably necessary to fulfill the specific purposes for which we collected your information and to prevent persistent identifiers from being retained indefinitely. In addition to a retention policy, Roblox employs measures including access controls, purpose-based tagging, employee training, and data segregation to manage the data we process. Roblox may retain the persistent identifiers that we collect from you for different periods of time based on our specific business needs... For safety and security purposes (e.g., bot prevention), Roblox may process persistent identifiers for up to two years after account deletion.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: This provision interacts with GDPR Article 5(1)(e)'s storage limitation principle, which requires personal data to be kept no longer than necessary for specified purposes. The two-year post-deletion retention window for persistent identifiers requires a documented legal basis and must be assessed against the proportionality standard. CCPA and CPRA create rights to know about retention periods and to request deletion, with exceptions for security and legal compliance purposes. COPPA's retention guidelines also apply to identifiers collected from child users. 2. GOVERNANCE EXPOSURE: Medium. The two-year post-deletion retention of persistent identifiers for safety purposes is a defined and disclosed retention period, but the operational scope of what constitutes a safety or security purpose (beyond bot prevention) is not fully specified in this provision. 3. JURISDICTION FLAGS: EU/EEA users have the strongest rights to challenge retention periods under GDPR's storage limitation principle and the right to erasure under Article 17. California users have CCPA deletion rights subject to security exceptions. Brazil's LGPD imposes similar retention and deletion obligations. 4. CONTRACT AND VENDOR IMPLICATIONS: Service providers retaining data on behalf of Roblox after account deletion must operate within contractual retention limits that reflect the stated two-year window and the policy's stated deletion obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that technical deletion workflows are configured to initiate permanent deletion upon account closure and that the two-year safety retention window is enforced only for persistent identifiers and only for documented safety and security purposes, with appropriate access controls applied to post-deletion retained data.
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This provision establishes a stated retention framework and specifies a two-year post-deletion retention window for persistent identifiers for safety and security purposes. The two-year post-deletion retention period is an operationally significant disclosure for users who delete their accounts, as identifiers including IP addresses and device identifiers may continue to be processed during that period.
Under this provision, account deletion initiates permanent deletion of personal data in Roblox's systems, but persistent identifiers such as IP addresses and device identifiers may be retained and processed for safety and security purposes for up to two years after deletion. The agreement also states that data may be retained longer if required for legal or regulatory compliance.
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