Roblox shares device identifiers and IP addresses of children under 13 with third-party service providers, subject to contracts meant to protect that data.
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 clause establishes the operational framework under which Roblox may disclose persistent identifiers of child users to third-party service providers, while specifying that such disclosure requires contractual safeguards and security protections as the mechanism for compliance with data protection obligations.
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 →Your child's device identifier and IP address may be processed by Roblox's third-party service providers, not just Roblox itself. Parents should be aware that these providers are contractually restricted from using this data for purposes beyond supporting Roblox's internal operations, but the specific vendors are not named in this provision.
How other platforms handle this
Our Service Providers: We share your Personal Information with third-party service providers that provide services on our behalf; for example, we use Stripe (a third party payment provider) to receive and process your credit card transactions for us. Such third parties further include, but are not l...
We may share your personal information with: Service providers who perform services on our behalf. Financial partners, such as banks, payment processors, and financial institutions. Professional advisors, such as lawyers, auditors, and insurers. Business partners with whom we jointly offer products ...
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
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"Roblox relies on service providers to support the internal operations described above. 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 and other measures to protect the security, confidentiality, and integrity of the information.— Excerpt from Roblox's Roblox Privacy and Cookie Policy
REGULATORY LANDSCAPE: Under COPPA, operators may disclose children's personal information (including persistent identifiers) to service providers supporting internal operations, provided the service provider is contractually prohibited from using the data for any other purpose. The FTC's COPPA Rule Section 312.5(b)(2) governs this exception. Any service provider use of children's persistent identifiers beyond the enumerated internal operations without verifiable parental consent would implicate COPPA liability for Roblox as the operator. GOVERNANCE EXPOSURE: Medium. The policy asserts contractual protections but does not specify what auditing or enforcement mechanisms are in place to verify service provider compliance. Roblox's liability for service provider misuse of children's data remains relevant under COPPA's operator responsibility framework. JURISDICTION FLAGS: This provision is primarily a COPPA (US federal) compliance matter. Under GDPR, sharing personal data of minors with processors requires GDPR Article 28 compliant data processing agreements. The intersection of COPPA service provider rules and GDPR processor requirements creates dual compliance obligations for vendors processing data of users who may be EU residents under 13. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should maintain a current list of service providers processing persistent identifiers of under-13 users and confirm that each has a signed, COPPA-compliant data processing agreement in place. Agreements should specify permitted uses, security requirements, breach notification timelines, and deletion obligations. Audit rights should be included. COMPLIANCE CONSIDERATIONS: Legal teams should request and review copies of data processing agreements with service providers handling children's persistent identifiers. An annual vendor review process should confirm that service providers remain compliant with contractual restrictions. Data breach response procedures should address scenarios where a service provider experiences a breach involving children's persistent identifiers.
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The clause establishes the operational framework under which Roblox may disclose persistent identifiers of child users to third-party service providers, while specifying that such disclosure requires contractual safeguards and security protections as the mechanism for compliance with data protection obligations.
Your child's device identifier and IP address may be processed by Roblox's third-party service providers, not just Roblox itself. Parents should be aware that these providers are contractually restricted from using this data for purposes beyond supporting Roblox's internal operations, but the specific vendors are not named in this provision.
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