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 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 →Removal of explicit persistent identifier disclosure for children (IP address and device identifiers) may obscure technical data collection practices previously disclosed to parents and guardians.
View full 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
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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.
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