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
Under COPPA, persistent identifiers collected from children under 13 that can be used to recognize a child across platforms or over time are treated as personal information. The use of persistent identifiers for contextual advertising, even frequency capping, requires careful alignment with COPPA's internal operations exception.
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…
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…
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…
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.
How other platforms handle this
Depending on where you live, you may have certain rights with respect to your personal information. These rights may include: The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected i...
Replit does not knowingly collect personal information from children under 13. Users between the ages of 13 and 18 may use the platform with parental or guardian consent. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will delete...
If you are located in the EEA, UK, or Switzerland, you have certain rights with respect to your personal information, including the right to access your personal data, to correct or delete your personal data, to restrict processing of your personal data, to data portability, and to object to process...
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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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Under COPPA, persistent identifiers collected from children under 13 that can be used to recognize a child across platforms or over time are treated as personal information. The use of persistent identifiers for contextual advertising, even frequency capping, requires careful alignment with COPPA's internal operations exception.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.