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For users under 13, Roblox states it collects username, password, date of birth, optional gender, and persistent identifiers (IP address and device identifiers) for internal operations, asserting this collection is consistent with COPPA's definition of non-personal information.
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 the operational boundaries for child data collection under COPPA and determines which platform features are accessible to users under 13, including the exclusion of personalized advertising until age 18.
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 →Under these terms, children under 13 have restricted access to platform features including personalized advertising and certain alerts; the agreement establishes that data collected from under-13 users is limited to COPPA-defined non-personal information and persistent identifiers for internal operations. Parents or guardians can request review, deletion, or restriction of a child's data through the Roblox Customer Support Form.
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"If you're under 13 years old and create an account, we ask for some information (which is non-personal information, as defined by COPPA) to let you use Roblox. We'll collect: your username (required). We need this to create your account and run the Roblox Service. We don't use your username to identify you outside of Roblox your password (required). We need this to log you in to your account and to run the Roblox Service your date of birth (required). We'll use this information to make sure your account has certain default settings intended for your age your gender (optional).Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: This provision directly engages COPPA (enforced by the FTC), which restricts collection of personal information from children under 13 without verifiable parental consent. The policy asserts that collected information for under-13 users is non-personal as defined by COPPA, but the collection of persistent identifiers (IP addresses, device IDs) for internal operations is specifically addressed under COPPA's operator provisions. FTC enforcement of COPPA is active and has resulted in significant penalties against gaming and social platforms. (2) GOVERNANCE EXPOSURE: High. The policy states that persistent identifiers are collected from under-13 users for internal operations including contextual advertising (capping ad frequency) and user authentication. Compliance teams should verify that contextual advertising use of persistent identifiers from under-13 users is consistent with COPPA's operator exception for internal operations, particularly given FTC guidance on this exception's scope. (3) JURISDICTION FLAGS: US federal COPPA is the primary framework. Additionally, state-level children's privacy laws in California (AADC), Illinois, and other states may impose additional consent or data minimization requirements beyond COPPA. The UK's Age Appropriate Design Code (AADC) applies to EEA/UK users and may require additional assessment of the platform's default privacy settings for children. (4) CONTRACT AND VENDOR IMPLICATIONS: The policy names service providers that may process persistent identifiers from under-13 users (including analytics and billing providers). COPPA requires that operators contractually prohibit service providers from using children's data for unauthorized purposes, and compliance teams should verify these contractual restrictions are in place with all named and unnamed vendors. (5) COMPLIANCE CONSIDERATIONS: Legal teams should audit whether the parental consent and notification workflows described in the policy (including the 24-hour email deletion window for unlinked parent accounts) are operationally implemented, and whether the contextual advertising use of persistent identifiers from under-13 users is documented as an internal operations exception under COPPA guidelines.
This provision establishes the operational boundaries for child data collection under COPPA and determines which platform features are accessible to users under 13, including the exclusion of personalized advertising until age 18.
Under these terms, children under 13 have restricted access to platform features including personalized advertising and certain alerts; the agreement establishes that data collected from under-13 users is limited to COPPA-defined non-personal information and persistent identifiers for internal operations. Parents or guardians can request review, deletion, or restriction of a child's data through the Roblox Customer Support Form.
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