The April 30, 2026 update adds language to the policy describing Roblox's practices for sharing user information with law enforcement and government authorities. The specific scope and conditions of this sharing are described in the updated policy body.
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
This provision discloses that Roblox shares user information with law enforcement and government authorities, a practice with significant implications for user privacy and for compliance with legal process obligations under applicable law. The provision is newly added as of the April 2026 effective date.
Interpretive note: The full language of the law enforcement sharing provision is referenced in the change summary but the complete operative text was not available in the provided document excerpt, limiting assessment of its scope and conditions.
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 updated policy discloses that Roblox shares personal information with law enforcement and government authorities under conditions described in the policy. The agreement does not specify whether users are notified prior to or following such disclosures.
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"We added language describing our practices for sharing information with authorities.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: Law enforcement data sharing practices interact with the Electronic Communications Privacy Act (ECPA), the Stored Communications Act (18 U.S.C. Chapter 121), and applicable state law. For EU and UK users, such sharing may implicate GDPR Article 6 legal basis requirements and Article 49 restrictions on international transfers to law enforcement. Brazil's LGPD similarly imposes conditions on sharing with public authorities. 2. GOVERNANCE EXPOSURE: Medium. The policy's disclosure of law enforcement sharing practices is a standard provision, but the absence of a stated user notification policy (such as notice prior to or following disclosure where legally permitted) may be relevant for platforms operating in jurisdictions that require or encourage such transparency. 3. JURISDICTION FLAGS: EU and UK users have heightened exposure given GDPR restrictions on transfers to non-EU law enforcement and the requirement for a valid legal basis for any processing. California residents may have rights under CCPA exceptions applicable to law enforcement disclosures. 4. CONTRACT AND VENDOR IMPLICATIONS: This provision does not directly create vendor or B2B contract implications, but organizations using Roblox for enterprise or educational purposes should be aware that user data may be disclosed to authorities in response to legal process without necessarily notifying the affected user. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should review whether the policy's law enforcement sharing language aligns with applicable legal process obligations and whether the platform maintains a transparency report or law enforcement guidelines document that supplements this policy provision.
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This provision discloses that Roblox shares user information with law enforcement and government authorities, a practice with significant implications for user privacy and for compliance with legal process obligations under applicable law. The provision is newly added as of the April 2026 effective date.
The updated policy discloses that Roblox shares personal information with law enforcement and government authorities under conditions described in the policy. The agreement does not specify whether users are notified prior to or following such disclosures.
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