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The policy states that Personal Information may be transferred to acquiring entities in merger, acquisition, asset sale, insolvency, bankruptcy, or receivership scenarios, with notice and consent required only where mandated by applicable law.
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 conditions under which user Personal Information, including data from minors, may be transferred to third-party entities in corporate transactions, with the consent requirement conditioned on applicable law rather than applied universally.
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, Roblox may transfer user Personal Information to a successor entity in a corporate transaction; the agreement conditions notice and consent obligations on applicable law rather than applying them universally across all jurisdictions. Users in jurisdictions where law requires notice or consent would receive that protection; users in other jurisdictions may not.
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"We may hand over rights to access your information, including Personal Information: as part of a merger, acquisition, sale of assets, or similar transaction if information is handed over as a business asset in an insolvency, bankruptcy, or receivership Where required by law, we will notify you and ask you to consent to such sharing.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: GDPR requires that data transfers in M&A scenarios are subject to the same lawful basis requirements as initial collection, and that data subjects retain their rights against the acquiring entity. COPPA requires that operators obtain new verifiable parental consent if an acquiring company intends to change data practices materially. The FTC Act applies to whether post-acquisition data practices are consistent with representations made to users at time of collection. (2) GOVERNANCE EXPOSURE: Medium. The conditioning of notice and consent on applicable law means that in many jurisdictions, users would have no advance notification of or consent right over transfer of their data to an acquirer. For child users under 13, COPPA imposes specific requirements on the acquiring entity regarding continuity of consent and data practice disclosures. (3) JURISDICTION FLAGS: EEA users retain GDPR rights against the acquiring entity. California residents have CCPA notification rights in certain asset transfer scenarios. COPPA creates specific obligations for any acquirer of a children's platform regarding existing data and consent. (4) CONTRACT AND VENDOR IMPLICATIONS: Due diligence in any acquisition of Roblox would require assessment of data processing agreements, COPPA consent records, GDPR lawful basis documentation, and biometric data consent records given the range of data types described in this policy. (5) COMPLIANCE CONSIDERATIONS: Legal teams advising on transactions involving Roblox should assess whether COPPA consent records are transferable and sufficient for post-acquisition operations, and whether GDPR lawful basis for existing processing would survive a change of controller.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes the conditions under which user Personal Information, including data from minors, may be transferred to third-party entities in corporate transactions, with the consent requirement conditioned on applicable law rather than applied universally.
Under these terms, Roblox may transfer user Personal Information to a successor entity in a corporate transaction; the agreement conditions notice and consent obligations on applicable law rather than applying them universally across all jurisdictions. Users in jurisdictions where law requires notice or consent would receive that protection; users in other jurisdictions may not.
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