Roblox shares your personal information with service providers, advertising and analytics companies, business partners, and in the event of a corporate sale or merger. Service providers are contractually restricted to using data only as Roblox directs.
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 the categories of third parties that receive your personal data and the conditions under which sharing occurs, including advertising partners and corporate transaction scenarios where data may transfer to a new entity.
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 →Removal of broad third-party sharing framework, particularly advertising and analytics partner sharing, reflects tightening of data sharing practices for compliance with child privacy regulations.
View full change record →This new provision explicitly documents all third-party data sharing scenarios including merger/acquisition conditions, providing clarity on when user data may be transferred to external parties.
View full change record →Your personal information including identifiers, behavioral data, and device information may be shared with advertising partners, analytics companies, and business partners; in the event of a merger or acquisition, your data may be transferred to a new corporate owner under this provision.
How other platforms handle this
By using the Services, you authorize Affirm to share your information, including personal information and information related to your transactions and use of the Services, with merchants, service providers, and other third parties as further described in our Privacy Policy.
We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...
Sending you information about Adobe products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes, where your consent is not required; In some cases, in order to show you more relevant ads, we disclose with social medi...
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"We may share your personal information with third parties in the following circumstances: with service providers who perform services on our behalf; with advertising and analytics partners; with business partners with whom we jointly offer products or services; with other parties with your consent; in connection with a merger, acquisition, or sale of assets; and as required by law or legal process. Our service providers are contractually required to use your information only as directed by us and in accordance with this Privacy Policy.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14 (transparency about data recipients), CCPA requirements to disclose categories of third parties to whom personal information is disclosed, and general FTC Act Section 5 requirements regarding material disclosures about data sharing. Corporate transaction data transfers engage GDPR Article 6 lawful basis requirements and may require data subject notification. (2) GOVERNANCE EXPOSURE: Medium. The disclosure of advertising and analytics partners as data recipients is standard in the industry but creates CCPA 'sharing' obligations requiring opt-out rights; the corporate transaction carve-out is standard but should be evaluated for GDPR adequacy in cross-border transfer scenarios. (3) JURISDICTION FLAGS: EU/EEA users have rights to know the identity of data recipients and may have rights to object to sharing for legitimate interest purposes; California users have opt-out rights for data shared with advertising partners; cross-border transfers to non-adequate countries require appropriate transfer mechanisms under GDPR Chapter V. (4) CONTRACT AND VENDOR IMPLICATIONS: Service provider contracts must include data processing agreements meeting GDPR Article 28 and CCPA service provider requirements; business partner agreements should include appropriate data use restrictions; corporate transaction agreements should address data transfer obligations and notification requirements. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain an updated inventory of third-party data recipients; verify that advertising and analytics partner agreements include appropriate restrictions; assess whether corporate transaction data transfer procedures include privacy review and, where required, data subject notification; and review international data transfer mechanisms for non-EU/UK data transfers.
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This provision establishes the categories of third parties that receive your personal data and the conditions under which sharing occurs, including advertising partners and corporate transaction scenarios where data may transfer to a new entity.
Your personal information including identifiers, behavioral data, and device information may be shared with advertising partners, analytics companies, and business partners; in the event of a merger or acquisition, your data may be transferred to a new corporate owner under this provision.
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