Reasonable steps taken to protect privacy rights on international transfer

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.

The updated policy explicitly discloses that Roblox collects persistent identifiers such as IP addresses and unique device identifiers from all users, including children under 13, for internal operations including account maintenance, security, contextual advertising, and frequency capping. The policy states that Roblox implements technical and contractual measures to limit use of these identifiers to the stated purposes, and maintains a retention policy designed to limit data retention to what is reasonably necessary. For users under 13, the policy adds disclosure that Roblox may collect facial images to perform age assurance, with such images deleted once the age assurance process is complete. Parents can provide an email address to establish a parental account, and Roblox will delete the parent's email within 24 hours if the linking process is not completed.