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The policy states that Roblox collects IP addresses and unique device identifiers from users including those under 13, and uses these persistent identifiers for six specified internal operations including contextual advertising and content personalization. The policy states that technical and contractual measures are implemented to prevent use of persistent identifiers beyond these stated purposes.
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 authorizes collection of IP addresses and device identifiers from child users under the COPPA internal operations exception, which permits such collection without verifiable parental consent when limited to the specified purposes. The inclusion of contextual advertising within the permitted internal operations is a notable disclosure, as COPPA's internal operations exception does not permit behavioral advertising to children.
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 →Explicitly carves out exception allowing persistent identifier collection for children for core service functionality, clarifying what data collection remains permissible under COPPA compliance.
View full change record →Under this provision, Roblox collects IP addresses and unique device identifiers from all users including those under 13 for purposes including platform maintenance, authentication, contextual advertising, and security. The agreement states that contractual and technical measures restrict use of these identifiers to the six listed purposes.
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"When children sign up for Roblox, we also collect certain types of personal information called persistent identifiers for internal operations and to provide you and other users with Services. Persistent identifiers are data like IP Address and unique device identifiers that are required for you to be able to connect your device to Roblox. Persistent identifiers can be used to recognize you, your device, or your household device. Roblox collects persistent identifiers and the information we ask you for when you sign up for the following internal operations: Maintaining or analyzing the functioning of Roblox; Performing network communications; Authenticating users of, or personalizing the content on, Roblox; Serving contextual advertising, including capping the frequency of ads; Protecting the security or integrity of Roblox; Ensuring legal or regulatory compliance.Excerpt from Roblox's Privacy and Cookie Policy
1. REGULATORY LANDSCAPE: This provision directly engages COPPA's internal operations exception (16 CFR 312.5(c)(7)), which permits collection of persistent identifiers from children under 13 without verifiable parental consent when limited to specified internal operations. The FTC has provided guidance on what constitutes a permissible internal operation. The provision's inclusion of contextual advertising as a permitted purpose is consistent with FTC guidance, which distinguishes contextual advertising from behavioral advertising for purposes of the internal operations exception. GDPR Recital 47 and Article 6 are also relevant for EU users. 2. GOVERNANCE EXPOSURE: Medium. The operational boundary between permissible contextual advertising and impermissible behavioral advertising using persistent identifiers from child users is a recurring area of regulatory attention. The policy's statement that technical and contractual measures prevent use beyond stated purposes is a significant compliance representation that requires operational verification. 3. JURISDICTION FLAGS: US federal COPPA creates heightened exposure nationally. EU/EEA users have rights under GDPR, which imposes additional consent and legal basis requirements for processing identifiers. California's CCPA and CPRA create additional rights for California users regarding collection of personal information including device identifiers. 4. CONTRACT AND VENDOR IMPLICATIONS: Service providers processing persistent identifiers from under-13 users must operate within contractual restrictions aligned with the stated internal operations purposes. Advertising technology vendors operating within Roblox's ecosystem should be assessed to confirm they do not use child-user persistent identifiers for behavioral targeting. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should map persistent identifier data flows to confirm that advertising technology integrations do not use identifiers from under-13 users for purposes beyond contextual ad serving, and that frequency capping mechanisms do not create behavioral profiles that would exceed the internal operations exception.
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This provision authorizes collection of IP addresses and device identifiers from child users under the COPPA internal operations exception, which permits such collection without verifiable parental consent when limited to the specified purposes. The inclusion of contextual advertising within the permitted internal operations is a notable disclosure, as COPPA's internal operations exception does not permit behavioral advertising to children.
Under this provision, Roblox collects IP addresses and unique device identifiers from all users including those under 13 for purposes including platform maintenance, authentication, contextual advertising, and security. The agreement states that contractual and technical measures restrict use of these identifiers to the six listed purposes.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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