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
The provision creates a procedural framework for regulatory compliance in jurisdictions requiring organizations to designate representatives for data subject inquiries and supervisory authority communications. Designating these contacts fulfills mandatory GDPR requirements and establishes the formal channels through which regulatory and individual data protection requests must be routed.
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 →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.
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 - Roblox, Grüffkamp 10, 24159 Kiel, Germany, roblox@dp-officer.com.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
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.
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The provision creates a procedural framework for regulatory compliance in jurisdictions requiring organizations to designate representatives for data subject inquiries and supervisory authority communications. Designating these contacts fulfills mandatory GDPR requirements and establishes the formal channels through which regulatory and individual data protection requests must be routed.
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.
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