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Roblox states it may collect images including selfies to perform facial age estimation, asserting that such images are deleted once the age assurance process is complete.
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 facial estimation mechanism for age assurance that involves biometric-adjacent data processing; applicable law in certain jurisdictions (including Illinois BIPA and GDPR's biometric data provisions) may impose consent, retention, and deletion obligations that require evaluation against the policy's stated deletion practice.
Interpretive note: Whether facial estimation generates biometric templates subject to BIPA or GDPR Article 9 protections prior to image deletion is not addressed in the quoted language, creating legal uncertainty regarding the full scope of biometric data processing.
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 clause, users may be asked to submit a selfie for facial age estimation purposes; the agreement states that images are deleted once the age assurance process is complete. The clause references a separate Roblox Facial Media Capture Policy for additional detail.
Cross-platform context
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"To assess user ages, Roblox may collect information about you, including images such as a selfie, to perform age assurance. Information collected to assess user ages, such as images taken to perform facial age estimation, is deleted once the age assurance process is complete. You can learn more about Roblox's practices in the Roblox Facial Media Capture Policy.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: Facial estimation data may constitute biometric data under GDPR Article 9 (requiring explicit consent and a specific exception) and under Illinois BIPA (requiring written consent and a public retention policy). The FTC has enforcement authority over deceptive or unfair biometric data practices under Section 5 of the FTC Act. The EU AI Act classifies certain biometric identification systems as high-risk, which may engage conformity assessment requirements. (2) GOVERNANCE EXPOSURE: High. The assertion that images are deleted post-process is operationally significant but difficult to verify externally. If facial estimation generates intermediate biometric templates before deletion, BIPA and GDPR Article 9 obligations may apply to those intermediate outputs even if the source image is deleted. Compliance teams should assess whether the deletion claim covers all derived data. (3) JURISDICTION FLAGS: Illinois BIPA creates the highest exposure given its private right of action and per-violation damages. Texas (CUBI) and Washington state biometric statutes also apply. For EEA users, GDPR Article 9 requires explicit consent for biometric processing. The policy's reference to a separate Facial Media Capture Policy creates a layered disclosure structure that should be reviewed for consistency. (4) CONTRACT AND VENDOR IMPLICATIONS: Roblox states age verification is conducted via a third-party vendor (referenced in context of identity verification). Third-party biometric data processing arrangements require GDPR Article 28 data processing agreements and BIPA-compliant vendor contracts including data retention and destruction schedules. (5) COMPLIANCE CONSIDERATIONS: Legal teams should review whether the Roblox Facial Media Capture Policy satisfies BIPA's written notice and consent requirements, whether a GDPR DPIA has been conducted for facial estimation processing, and whether the deletion assertion is operationally verifiable through technical audit or vendor certification.
This provision establishes a facial estimation mechanism for age assurance that involves biometric-adjacent data processing; applicable law in certain jurisdictions (including Illinois BIPA and GDPR's biometric data provisions) may impose consent, retention, and deletion obligations that require evaluation against the policy's stated deletion practice.
Under this clause, users may be asked to submit a selfie for facial age estimation purposes; the agreement states that images are deleted once the age assurance process is complete. The clause references a separate Roblox Facial Media Capture Policy for additional detail.
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