Roblox states it collects physical movement data from users on VR platforms for use within the VR experience, asserting that this data is not stored after use.
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
Physical movement data collected via VR platforms may constitute biometric or sensitive personal data under GDPR and certain US state statutes; the policy's assertion of non-storage is operationally significant but externally unverifiable without technical audit.
Interpretive note: Whether physical VR movement data constitutes biometric data subject to GDPR Article 9 or Illinois BIPA depends on whether the data enables unique identification, which is not addressed in the policy language.
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 discloses collection of VR motion data for experience provision with assurance it is not stored, expanding data collection to biometric movement information.
View full change record →Under these terms, users who join Roblox experiences on VR platforms have their physical movement data collected and used in real time within the experience; the agreement asserts this data is not stored. No user control mechanism for this collection is described in this provision.
Cross-platform context
See how other platforms handle VR Physical Movement Data Collection and similar clauses.
Compare across platforms →"If you join our experiences on a VR platform, we collect your physical movement information so that we can use it in the experience. This information is only used to provide the experience. We do not store this information.Excerpt from Roblox's Privacy and Cookie Policy
(1) REGULATORY LANDSCAPE: Physical movement data collected via VR may constitute biometric data under GDPR Article 9 if it enables unique identification, which would require explicit consent and a specific exception.
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Physical movement data collected via VR platforms may constitute biometric or sensitive personal data under GDPR and certain US state statutes; the policy's assertion of non-storage is operationally significant but externally unverifiable without technical audit.
Under these terms, users who join Roblox experiences on VR platforms have their physical movement data collected and used in real time within the experience; the agreement asserts this data is not stored. No user control mechanism for this collection is described in this provision.
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