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
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 →How other platforms handle this
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
"Wherever we transfer your Personal Information, we will take reasonable steps so that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.Excerpt from Roblox's Privacy and Cookie Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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The clause states: “Wherever we transfer your Personal Information, we will take reasonable steps so that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.”
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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