Roblox · Roblox Privacy and Cookie Policy · View original document ↗

GDPR and International Data Transfer Rights

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Recent governance activity Roblox recorded 22 documented changes in the last 30 days.
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Document Record

What it is

If you live in the EU, EEA, UK, or Switzerland, you have specific rights including accessing, correcting, deleting, or restricting your personal data, and you can contact Roblox's designated EU/UK representatives.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The clause operationalizes Roblox's obligation to maintain data protection standards during cross-border transfers while specifying reliance on legal transfer mechanisms (such as Standard Contractual Clauses or adequacy decisions) to comply with jurisdictional requirements governing international data flows.

Recent Activity

This document changed recently

Medium May 1, 2026

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 →
Medium Apr 23, 2026

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 →
Medium Mar 8, 2026

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 →

Consumer impact (what this means for users)

EU/EEA/UK users can exercise rights of access, erasure, portability, restriction, and objection under GDPR by contacting roblox@gdpr-rep.com or the designated country-specific DPO. These rights are legally enforceable and Roblox must respond within statutory timeframes.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Within 30 days
    EU/EEA/UK users can email roblox@gdpr-rep.com to submit a data deletion, access, or portability request under GDPR. Include your account username and specify the right you wish to exercise.

How other platforms handle this

RapidAPI Medium

If you are located in the European Economic Area, you have certain rights under the General Data Protection Regulation. These include the right to access personal information we hold about you, to rectify inaccurate data, to erase your data, to restrict processing, to object to processing, and to da...

Notion Medium

Depending on where you live, you may have certain rights regarding your personal information. For example, you may have the right to: Access your personal information; Correct inaccurate personal information; Request deletion of your personal information; Object to or restrict processing of your per...

X Medium

If you are located in the European Economic Area (EEA) or United Kingdom, the data controller for your personal information is Twitter International Unlimited Company. If you are located outside of the EEA, United Kingdom, and Switzerland, the data controller is X Corp. You have the right to access,...

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▸ View Original Clause Language DOCUMENT RECORD
"
Wherever we transfer your Personal Information, we will take reasonable steps so that your privacy rights continue to be protected. If required by applicable legislation, we rely on a valid international data transfer mechanism to enable cross-border data transfers.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

Roblox has appointed Article 27 GDPR representatives in the EU and UK (DP-Dock GmbH and DP Data Protection Services UK Ltd.) and an Article 37 DPO, indicating awareness of its obligations as a data controller established outside the EEA/UK. Risk teams should assess the adequacy of Roblox's international data transfer mechanisms (e.g., Standard Contractual Clauses) for transfers of EEA/UK user data to US-based infrastructure.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
March 8, 2026
Last verified
March 9, 2026
Record ID
CA-P-000603
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fa9d5a08d4ef18168a5c8629e70fcdda838a1e1cb7da1a0da12925d6a5d38cc0
Analysis generated
March 8, 2026 18:35 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-000603
Captured: 2026-03-08 18:35:41 UTC
SHA-256: fa9d5a08d4ef1816…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/gdpr-and-international-data-transfer-rights/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Roblox's GDPR and International Data Transfer Rights clause do?

The clause operationalizes Roblox's obligation to maintain data protection standards during cross-border transfers while specifying reliance on legal transfer mechanisms (such as Standard Contractual Clauses or adequacy decisions) to comply with jurisdictional requirements governing international data flows.

How does this clause affect you?

EU/EEA/UK users can exercise rights of access, erasure, portability, restriction, and objection under GDPR by contacting roblox@gdpr-rep.com or the designated country-specific DPO. These rights are legally enforceable and Roblox must respond within statutory timeframes.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.