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
Third-party service providers processing persistent identifiers of children under 13 extend the reach of children's data beyond Roblox itself. The adequacy of contractual protections and Roblox's ability to audit and enforce those protections is a key COPPA compliance consideration.
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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 includin…
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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
We may share your personal data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We may also share your personal data with advertising partners to display relevant advertising to y...
We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...
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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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Third-party service providers processing persistent identifiers of children under 13 extend the reach of children's data beyond Roblox itself. The adequacy of contractual protections and Roblox's ability to audit and enforce those protections is a key COPPA compliance consideration.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.