For users 13 and older, Roblox states it monitors, collects, uses, and stores audio captured through users' devices for voice chat enablement, safety enforcement, AI model training, and product improvement 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 establishes that audio recordings are used for AI training and product improvement in addition to safety purposes, which engages GDPR lawful basis requirements, US state voice data statutes, and EU AI Act training data transparency obligations depending on user jurisdiction.
Interpretive note: The lawful basis asserted for AI training use of audio data is not specified per jurisdiction in the quoted language, creating interpretive uncertainty regarding GDPR compliance.
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 →New provision establishes Roblox's collection and use of audio data for voice chat, safety monitoring, and AI training purposes, which represents expanded data collection beyond previous policies.
View full change record →This provision establishes that audio captured during Roblox sessions for users 13 and older may be retained and used to inform AI training and product improvement, in addition to voice chat and safety functions. The agreement requires compliance with applicable law for audio processing, though the specific consent mechanism or lawful basis asserted varies by jurisdiction.
Cross-platform context
See how other platforms handle Audio Data Collection and AI Training and similar clauses.
Compare across platforms →"If you use Roblox's audio features, we will monitor, collect, use, and store audio captured through your device: to enable voice chat, to make our voice-related services safer, including to detect and combat abuse and other harmful activity on our Services, in accordance with applicable law, to inform training and product improvement, and in connection with screen recordings that Creators and Users produce through the Services.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 (lawful basis) and potentially Article 9 if voice prints constitute biometric data under EU interpretation, enforced by EEA data protection authorities.
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This provision establishes that audio recordings are used for AI training and product improvement in addition to safety purposes, which engages GDPR lawful basis requirements, US state voice data statutes, and EU AI Act training data transparency obligations depending on user jurisdiction.
This provision establishes that audio captured during Roblox sessions for users 13 and older may be retained and used to inform AI training and product improvement, in addition to voice chat and safety functions. The agreement requires compliance with applicable law for audio processing, though the specific consent mechanism or lawful basis asserted varies by jurisdiction.
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