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

International Data Transfers and Standard Contractual Clauses

Medium severity Rare · 5 of 325 platforms
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Recent governance activity Roblox recorded 18 documented changes in the last 30 days.
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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)

International data transfers from the EU/EEA to the US remain a legally contested area following Schrems II; reliance on SCCs requires Roblox to conduct Transfer Impact Assessments and implement supplementary measures, failure of which could expose EU user data to regulatory challenge.

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)

Roblox's policy authorizes collection of identifiers, device data, in-game behavioral data, chat and communications content, location-related data, and payment information, and permits sharing this data with advertising and analytics partners for cross-context behavioral advertising for eligible age users. Users in applicable jurisdictions have rights to access, correct, delete, or restrict processing of their personal data, and California residents have the right to opt out of the sale or sharing of personal information. You can submit a data rights request or opt out of data sharing by visiting https://www.roblox.com/my/account#!/privacy or contacting privacy@roblox.com.

How other platforms handle this

OneLogin Medium

If you are located in the European Economic Area, the United Kingdom, or Switzerland, please be aware that we may transfer your personal information to countries outside of these regions, including to the United States, where data protection laws may not provide the same level of protection as those...

Zendesk Medium

Where Zendesk transfers personal data outside of the European Economic Area, the United Kingdom, or Switzerland, we rely on appropriate transfer mechanisms, including Standard Contractual Clauses approved by the European Commission, to ensure that your personal data receives an adequate level of pro...

Pinterest Medium

Pinterest, Inc. 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 we transfer your personal data from the EEA, Switzerland, or the UK to...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located outside of the United States, your personal information may be transferred to and processed in the United States or other countries. We use Standard Contractual Clauses approved by the European Commission and other appropriate safeguards to transfer personal data from the EU/EEA and UK to countries that have not been deemed to provide an adequate level of data protection.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

Applicable regulations

CCPA/CPRA
California, USA
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-006121
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
65526103181ac7fe55d4543ce0b351c34dc032fe69a8add53e6f30543ae9d94a
Analysis generated
May 12, 2026 09:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-006121
Captured: 2026-05-12 09:41:40 UTC
SHA-256: 65526103181ac7fe…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/international-data-transfers-and-standard-contractual-clauses/
Accessed: May 13, 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 International Data Transfers and Standard Contractual Clauses clause do?

International data transfers from the EU/EEA to the US remain a legally contested area following Schrems II; reliance on SCCs requires Roblox to conduct Transfer Impact Assessments and implement supplementary measures, failure of which could expose EU user data to regulatory challenge.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 5 platforms. See the full comparison.

Is ConductAtlas affiliated with Roblox?

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