The policy appoints Article 27 EU and UK GDPR representatives and an Article 37 DPO for EU users, and provides separate contact details for EEA, UK, Switzerland, Brazil, Korea, and US state privacy requests. Region-specific addenda govern additional rights for users in those jurisdictions.
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 appointment of Article 27 representatives and an Article 37 DPO reflects compliance with GDPR requirements for non-EU controllers processing EU personal data. The policy's multi-jurisdictional structure, including separate addenda for US states, Brazil, and Korea, creates a layered compliance framework where the addenda govern over the main policy in case of conflict.
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 states that in the event of conflict between Sections 1-5 of the policy and the location-specific Section 8, Section 8 prevails, giving regional addenda governing authority over core policy terms for users in those jurisdictions. EU, UK, and EEA users can contact the designated Article 27 representative or DPO for privacy requests.
How other platforms handle this
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.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
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"If you're in the European Economic Area (EEA), the United Kingdom, or Switzerland: contact roblox@gdpr-rep.com (Our representative according to Articles 27 EU and UK GDPR in the European Union)... Our data protection officer in the EU according to Art. 37 GDPR can be reached via: DP Dock DPO Services GmbH— Excerpt from Roblox's Roblox Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: This provision reflects Roblox's compliance obligations under GDPR Articles 27 (EU/UK representative) and 37 (DPO) for non-EU/UK controllers processing personal data of EU/UK residents. Brazil's LGPD, Korea's PIPA, and US state privacy laws including California's CCPA/CPRA similarly impose jurisdiction-specific obligations addressed through the policy's addendum structure. 2. GOVERNANCE EXPOSURE: Medium. The multi-layered policy structure, in which addenda prevail over the core policy in case of conflict, requires that compliance teams maintain current versions of all regional addenda and ensure operational consistency between core policy representations and addendum provisions. 3. JURISDICTION FLAGS: EU/EEA, UK, Switzerland, Brazil, and Korea create the highest jurisdictional compliance exposure given their explicit identification in the policy. The US State Privacy Policy Addendum creates exposure across multiple US states with distinct privacy frameworks. 4. CONTRACT AND VENDOR IMPLICATIONS: International data transfer mechanisms (such as Standard Contractual Clauses or the EU-US Data Privacy Framework) are not explicitly described in the provided excerpt, but are required for lawful personal data transfers from the EU/EEA to the US under GDPR Chapter V. Compliance teams should confirm that transfer impact assessments and applicable transfer mechanisms are in place and reflected in the policy or its addenda. 5. COMPLIANCE CONSIDERATIONS: Legal teams should review the regional addenda (US State, Brazil, Korea) alongside the core policy to identify any provisions where the addendum supersedes the core policy, and ensure that operational data practices reflect the most restrictive applicable requirements. DPO and Article 27 representative appointment records should be maintained and registered with relevant supervisory authorities where required.
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The appointment of Article 27 representatives and an Article 37 DPO reflects compliance with GDPR requirements for non-EU controllers processing EU personal data. The policy's multi-jurisdictional structure, including separate addenda for US states, Brazil, and Korea, creates a layered compliance framework where the addenda govern over the main policy in case of conflict.
The policy states that in the event of conflict between Sections 1-5 of the policy and the location-specific Section 8, Section 8 prevails, giving regional addenda governing authority over core policy terms for users in those jurisdictions. EU, UK, and EEA users can contact the designated Article 27 representative or DPO for privacy requests.
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