The policy states that Roblox may collect facial images, including selfies, to estimate user age, and that such images are deleted once the age assurance process is complete. A separate Roblox Facial Media Capture Policy governs additional details of this practice.
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 authorizes collection of facial images for age estimation purposes, which may trigger obligations under state biometric privacy statutes including Illinois BIPA and Texas CUBI, depending on whether facial geometry data is derived from the images during processing. The stated deletion upon process completion is relevant to retention obligations under those frameworks, but does not necessarily resolve all consent or notice requirements.
Interpretive note: Whether the facial image collection constitutes biometric data under state statutes such as Illinois BIPA depends on whether facial geometry templates are extracted during processing, which is not specified in this provision.
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 →Shifted from general biometric collection framework to specific age assurance use case with explicit deletion guarantee post-assessment and reference to separate facial media policy.
View full change record →Under this provision, Roblox may collect a facial image from a user to estimate their age, and the agreement states the image is deleted once the assurance process concludes. The scope of data generated during processing (such as derived facial geometry) and whether that constitutes separately regulated biometric data depends on applicable state law.
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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 Roblox Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: This provision may require evaluation under Illinois BIPA (740 ILCS 14), Texas CUBI, and Washington's My Health MY Data Act, as well as the EU GDPR's provisions on biometric data as a special category under Article 9. The FTC's general authority over unfair or deceptive data practices is also relevant. State biometric privacy statutes generally require prior written consent and a publicly available retention and destruction policy before collecting biometric identifiers or biometric information; whether facial images used for age estimation qualify depends on whether geometric or template data is extracted during processing. 2. GOVERNANCE EXPOSURE: High. Illinois BIPA provides a private right of action with statutory damages of $1,000 to $5,000 per violation, creating significant class action exposure for any platform collecting facial data from Illinois residents without compliant consent and retention policies. 3. JURISDICTION FLAGS: Illinois residents face the highest exposure given BIPA's private right of action. Texas and Washington residents may have rights under their respective statutes. EU and UK users may have rights under GDPR Article 9 special category protections, which require explicit consent or another valid legal basis for biometric processing. The policy's reference to a separate Facial Media Capture Policy means the full disclosure scope is not contained in this document alone. 4. CONTRACT AND VENDOR IMPLICATIONS: If age assurance is conducted by a third-party vendor, contractual data processing agreements should address BIPA-compliant consent collection, data minimization, and destruction obligations. Vendors processing facial images should be assessed for compliance with applicable biometric privacy statutes in jurisdictions where Roblox users are located. 5. COMPLIANCE CONSIDERATIONS: Legal teams should review the Roblox Facial Media Capture Policy in conjunction with this provision to assess the completeness of biometric data disclosures. Consent mechanism audits should confirm that BIPA-compliant written consent is obtained from Illinois users before facial image collection, and that the stated deletion-upon-completion practice is operationally enforced.
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This provision authorizes collection of facial images for age estimation purposes, which may trigger obligations under state biometric privacy statutes including Illinois BIPA and Texas CUBI, depending on whether facial geometry data is derived from the images during processing. The stated deletion upon process completion is relevant to retention obligations under those frameworks, but does not necessarily resolve all consent …
Under this provision, Roblox may collect a facial image from a user to estimate their age, and the agreement states the image is deleted once the assurance process concludes. The scope of data generated during processing (such as derived facial geometry) and whether that constitutes separately regulated biometric data depends on applicable state law.
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