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
The clause establishes the operational framework governing data lifecycle management, defining both the retention period (tied to service necessity and legal obligations) and the mechanism for disposition (deletion or anonymization). This structure allocates responsibility for data handling across multiple institutional purposes rather than a single predetermined retention schedule.
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 →Users' personal information remains subject to processing and storage while the identified purposes (service provision, legal compliance, dispute resolution, agreement enforcement) remain applicable. Upon conclusion of these purposes, the terms authorize but do not mandate immediate deletion, permitting anonymization as an alternative disposition method.
How other platforms handle this
We retain personal data for as long as needed to provide our services, comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will vary depending on the type of data and the purposes for which we use it.
Microsoft retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for differen...
We keep information as long as we need it to provide our products and services and fulfil the purposes described in this policy. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, relevant legal or operational retention ...
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"We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. When we no longer need personal information for these purposes, we will delete or anonymize it.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
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The clause establishes the operational framework governing data lifecycle management, defining both the retention period (tied to service necessity and legal obligations) and the mechanism for disposition (deletion or anonymization). This structure allocates responsibility for data handling across multiple institutional purposes rather than a single predetermined retention schedule.
Users' personal information remains subject to processing and storage while the identified purposes (service provision, legal compliance, dispute resolution, agreement enforcement) remain applicable. Upon conclusion of these purposes, the terms authorize but do not mandate immediate deletion, permitting anonymization as an alternative disposition method.
ConductAtlas has identified this type of provision across 66 platforms. See the full comparison.
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