With your explicit consent, Roblox may use your phone number to recommend you as a friend to others on the platform, displaying you under the name stored in their contacts — which may include your real name.
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 clause establishes a contact-matching mechanism that links phone numbers to friend recommendations, requiring explicit user consent to activate but permitting continued use of the feature unless affirmatively disabled. This creates a data processing pathway where phone number data interfaces with third-party device contacts.
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 you opt into the phone number discoverability feature, your real name (as stored in others' contacts) may become visible to other Roblox users. You can deactivate this feature at any time in your account settings.
How other platforms handle this
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 you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
Monitoring
Roblox has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"Additionally, with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Roblox. You will be recommended with your contact name as stored on your friends' devices, which may also include your real name. If you do not want us to use your phone number to be found by your friends on Roblox, please do not activate this feature or deactivate it at any time.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
The discoverability feature involves processing phone numbers and contact matching against third-party device contacts, raising concerns about data minimization under GDPR Article 5(1)(c) and the adequacy of consent mechanisms. The feature is unavailable in certain jurisdictions, suggesting awareness of regulatory restrictions.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
The clause establishes a contact-matching mechanism that links phone numbers to friend recommendations, requiring explicit user consent to activate but permitting continued use of the feature unless affirmatively disabled. This creates a data processing pathway where phone number data interfaces with third-party device contacts.
If you opt into the phone number discoverability feature, your real name (as stored in others' contacts) may become visible to other Roblox users. You can deactivate this feature at any time in your account settings.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.