Provision record
Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Service providers may process under-13 persistent identifiers

High severity Explicit document language Common · 288 of 352 platforms
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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

Recent Activity

This document changed recently

Medium May 1, 2026

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 →
Medium Mar 8, 2026

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 →

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 4429 other provisions on other platforms.

How other platforms handle this

Ancestry Medium

These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.

Lime Medium

if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services

Adobe Medium

We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
In some cases, these entities may process persistent identifiers from users under the age of 13. Service providers' processing of persistent identifiers to support these internal operations is subject to contractual requirements...

Excerpt from Roblox's Privacy and Cookie Policy

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-021662
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3faf31f6bd3ef98d563c5b3e6c035b59fd338cc62ace0a458b7078e1ad890dc6
Analysis generated
July 9, 2026 03:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-021662
Captured: 2026-07-09 03:33:11 UTC
SHA-256: 3faf31f6bd3ef98d…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/provision/CA-P-021662/service-providers-may-process-under-13-persistent-identifiers/
Accessed: Aug. 18, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's Service providers may process under-13 persistent identifiers clause do?

The clause states: “In some cases, these entities may process persistent identifiers from users under the age of 13. Service providers' processing of persistent identifiers to support these internal operations is subject to contractual requirements...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.