The updated policy adds new language explaining when and how Roblox may share user information with government authorities or law enforcement.
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 operationalizes Roblox's legal disclosure obligations and establishes the procedural basis under which user data may be released to governmental entities without independent user notice or consent, contingent on legal process or the company's assessment of legal necessity.
Interpretive note: The document's change summary references added language on authority sharing, but the full text of that provision was not reproduced in the available document excerpt, limiting assessment of its specific conditions and scope.
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 →The policy now includes provisions addressing when Roblox may share your personal data with authorities. Users should be aware that their account data, including communications and device identifiers, may be disclosed in response to legal requests, and the specific conditions and safeguards governing such disclosures are described in the policy.
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We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
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.
Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.
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"We added language describing our practices for sharing information with authorities.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
REGULATORY LANDSCAPE: Data sharing with authorities must comply with applicable legal process requirements in each jurisdiction. In the US, this typically requires a valid subpoena, court order, or warrant depending on the data category, with additional protections for content data under the Electronic Communications Privacy Act (ECPA). Under GDPR Article 6(1)(c) and Article 10, disclosures to public authorities must be grounded in Union or member state law and must not go beyond what is necessary. The FTC and EU data protection authorities are relevant enforcement bodies. GOVERNANCE EXPOSURE: Medium. The addition of explicit authority disclosure language is a transparency improvement, but the adequacy of the disclosure depends on the specificity of the conditions stated. Broad or discretionary language authorizing sharing with authorities without requiring legal compulsion may create tension with GDPR's necessity and proportionality requirements and with ECPA protections in the US. JURISDICTION FLAGS: EU and UK users have heightened protections against data transfers to non-EU public authorities under GDPR Chapter V and the Schrems II framework. Disclosures to US authorities of EU user data may require evaluation under applicable transfer mechanisms and the EU-US Data Privacy Framework. Brazilian LGPD similarly restricts sharing of personal data with public authorities to cases of legal obligation. CONTRACT AND VENDOR IMPLICATIONS: This provision is primarily a direct Roblox data practice rather than a vendor contract issue, but legal teams should confirm that data processing agreements with service providers address how authority requests for data held by vendors are handled and escalated to Roblox. COMPLIANCE CONSIDERATIONS: Legal teams should review the full text of the authority disclosure provision (summarized in the change log but not fully reproduced in the truncated document) to assess whether it limits disclosures to legally compelled requests or permits voluntary disclosures. A law enforcement response policy and request review process should be documented. For EU user data, the policy should address how Roblox evaluates and, where appropriate, challenges authority requests that may be incompatible with GDPR.
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The clause operationalizes Roblox's legal disclosure obligations and establishes the procedural basis under which user data may be released to governmental entities without independent user notice or consent, contingent on legal process or the company's assessment of legal necessity.
The policy now includes provisions addressing when Roblox may share your personal data with authorities. Users should be aware that their account data, including communications and device identifiers, may be disclosed in response to legal requests, and the specific conditions and safeguards governing such disclosures are described in the policy.
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