Even for children under 13, Roblox collects technical data like IP addresses and device IDs that can identify a child's device or household, and uses this data for purposes including serving contextual ads.
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 collection of persistent identifiers enables core platform operations including device connectivity, user recognition across sessions, and advertising delivery. This data collection supports both infrastructure maintenance and commercial functions within the service.
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 your child is under 13 and uses Roblox, the platform collects IP addresses and device identifiers from them, which can identify your household. These identifiers may be shared with service providers and used for contextual ad frequency capping, a practice that parents should understand when considering their child's use of the platform.
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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 we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
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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 Roblox Privacy and Cookie Policy
REGULATORY LANDSCAPE: COPPA (16 CFR Part 312) defines persistent identifiers such as IP addresses and device IDs as personal information when they can be used to recognize a child or device over time. The FTC's COPPA Rule permits collection of persistent identifiers from children under 13 without verifiable parental consent only for specifically enumerated internal operations, including those listed in this provision. Use of persistent identifiers for contextual advertising frequency capping sits at the boundary of the internal operations exception and has been an area of FTC scrutiny. GOVERNANCE EXPOSURE: High. The inclusion of contextual advertising frequency capping as a permitted use of persistent identifiers collected from under-13 users is consistent with the FTC's 2013 COPPA Rule amendments but remains a monitored area. Any use of persistent identifiers beyond the enumerated internal operations without verifiable parental consent would constitute a COPPA violation subject to civil penalties. JURISDICTION FLAGS: This provision is primarily a US federal (COPPA) compliance matter, with additional state-level exposure in California (CCPA minor provisions) and states with children's privacy laws. In the EU, GDPR applies to processing of personal data of children under 16 (or lower age set by member state law) and requires a legal basis distinct from the COPPA internal operations framework. CONTRACT AND VENDOR IMPLICATIONS: Service providers processing persistent identifiers of children under 13 must be subject to COPPA-compliant data processing contracts that prohibit use of the data for purposes beyond the enumerated internal operations. Roblox states it implements contractual requirements and other measures to this effect; these contracts should be audited to confirm restrictions are operationally enforced. COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the use of persistent identifiers for contextual advertising frequency capping falls within the FTC's internal operations exception and does not involve any cross-context behavioral tracking. Data mapping should identify all service providers receiving persistent identifiers from under-13 users and confirm each use case is covered by a COPPA-compliant legal basis. The retention period for persistent identifiers (up to two years post-account deletion for safety purposes) should be reviewed for proportionality under applicable law.
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The collection of persistent identifiers enables core platform operations including device connectivity, user recognition across sessions, and advertising delivery. This data collection supports both infrastructure maintenance and commercial functions within the service.
If your child is under 13 and uses Roblox, the platform collects IP addresses and device identifiers from them, which can identify your household. These identifiers may be shared with service providers and used for contextual ad frequency capping, a practice that parents should understand when considering their child's use of the platform.
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