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

GDPR Representative Appointment and International Compliance

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Document Record

What it is

Roblox has appointed a GDPR representative in the EU and a Data Protection Officer as required by European law, and provides specific contact details for EU, UK, Swiss, and Brazilian users to exercise their privacy rights.

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 appointment of a GDPR Article 27 representative and an Article 37 DPO indicates that Roblox is subject to and acknowledges GDPR obligations. EU and UK users can contact these designated representatives to exercise rights such as access, erasure, and objection to processing.

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…

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 includin…

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…

Consumer impact (what this means for users)

If you are in the EU, UK, or Switzerland, Roblox has designated specific contacts for privacy requests under GDPR, making it easier for you to exercise your data subject rights. EU users can contact roblox@gdpr-rep.com and the DPO at roblox@dp-officer.com for privacy concerns.

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
    EU, UK, and Swiss users can email roblox@gdpr-rep.com to submit data subject rights requests including access, erasure, or objection to processing. Include your account details and specify the right you wish to exercise.

How other platforms handle this

Waze Medium

If you are located in the European Economic Area or the United Kingdom, you have certain rights under applicable data protection laws, including the right to access, correct, or delete your personal data, the right to object to or restrict processing, and the right to data portability. You may also ...

McDonald's Medium

Our online services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible.

Zendesk Medium

Zendesk complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. When Zendesk transfers personal data from the EU, UK, or Switzerland to the United ...

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▸ View Original Clause Language DOCUMENT RECORD
"
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 - Roblox, Grüffkamp 10, 24159 Kiel, Germany, roblox@dp-officer.com.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: GDPR Article 27 requires non-EU controllers processing EU personal data to appoint a representative in the EU. Article 37 requires appointment of a DPO in specified circumstances, including where large-scale processing of personal data takes place. Roblox's explicit appointment of both a representative and a DPO demonstrates compliance with these structural GDPR requirements. Enforcement authority rests with EU member state data protection authorities and the UK ICO. GOVERNANCE EXPOSURE: Low for the appointment itself; the appointments are appropriate and consistent with GDPR requirements. However, the adequacy of the DPO's independence and the effectiveness of the representative in handling data subject requests in practice are operational matters that go beyond the policy text. JURISDICTION FLAGS: The appointments cover the EEA, UK, and Switzerland. Brazil is addressed separately with a designated DPO contact (dpo.roblox@leonardi.adv.br), reflecting LGPD requirements. Korea is addressed by a separate addendum. US state laws do not require DPO appointments but do require accessible privacy contact points, which this policy provides. CONTRACT AND VENDOR IMPLICATIONS: The existence of a DPO and GDPR representative is relevant for B2B partners and vendors who may need to identify the appropriate Roblox contact for data processing agreement negotiations or data subject request escalations. COMPLIANCE CONSIDERATIONS: Legal teams onboarding Roblox as a data processor or controller should verify that the appointed representative and DPO contacts are current and operationally responsive. Compliance teams should confirm that data subject rights requests routed through these contacts are fulfilled within GDPR's one-month response window. The policy should be reviewed to confirm that the legal bases for processing EU user data are documented in a Record of Processing Activities as required by GDPR Article 30.

Full compliance analysis

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

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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
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009293
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c6407ec7af45f80666fa8f24770b6c2c70801d3e6e370d2c57ff91c080cdfd3e
Analysis generated
May 10, 2026 16:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-009293
Captured: 2026-05-10 16:48:27 UTC
SHA-256: c6407ec7af45f806…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/gdpr-representative-appointment-and-international-compliance/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Roblox's GDPR Representative Appointment and International Compliance clause do?

The appointment of a GDPR Article 27 representative and an Article 37 DPO indicates that Roblox is subject to and acknowledges GDPR obligations. EU and UK users can contact these designated representatives to exercise rights such as access, erasure, and objection to processing.

How does this clause affect you?

If you are in the EU, UK, or Switzerland, Roblox has designated specific contacts for privacy requests under GDPR, making it easier for you to exercise your data subject rights. EU users can contact roblox@gdpr-rep.com and the DPO at roblox@dp-officer.com for privacy concerns.

Is ConductAtlas affiliated with Roblox?

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