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 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 →Provision name was clarified from 'Facial Image Collection for Age Assurance' to 'Facial Age Estimation and Age Assurance' but content remained identical.
View full 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
See how other platforms handle Facial Age Estimation and Age Assurance and similar clauses.
Compare across platforms →"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).
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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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