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The policy establishes that users under 18 receive only non-personalized advertisements, while users 18 and older may receive personalized advertisements, with consent required where applicable law mandates it. Users 18 and older can manage personalized ad preferences through account settings.
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
This provision establishes a platform-wide age gate for personalized advertising set at 18 rather than the COPPA threshold of 13, which represents a more restrictive advertising policy for the 13-17 age cohort and may interact with GDPR consent requirements for users in the EEA who are minors under applicable national law.
This clause establishes that users under 18 on Roblox will not receive personalized advertisements regardless of COPPA or GDPR minimum age thresholds, and that users 18 and older can control personalized ad delivery through Roblox account settings. Where consent is required by applicable law, the policy states consent will be obtained before personalized ads are served.
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"Users under 18 years old will see only nonpersonalized ads. Users 18 years old and older will see personalized ads on Roblox (with consent, where required). If you are 18 or older, you can control whether you see personalized ads through your Roblox settings.Excerpt from Roblox's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages COPPA's prohibition on behavioral advertising to users under 13, GDPR and UK GDPR consent requirements for advertising to minors, the EU Digital Services Act's prohibition on targeting minors based on profiling, and CCPA/CPRA restrictions on processing sensitive personal information of minors for advertising. The FTC enforces COPPA; EU data protection authorities and the European Commission enforce GDPR and DSA; California's CPPA enforces CCPA/CPRA. 2. GOVERNANCE EXPOSURE: Medium. The 18+ threshold for personalized advertising exceeds minimum legal requirements in most jurisdictions, reducing regulatory exposure in the 13-17 cohort. However, the policy's statement that consent is required 'where required' creates a jurisdiction-dependent consent framework that requires operationalization through verified age and consent mechanisms. The adequacy of age verification supporting this framework is material to its compliance effectiveness. 3. JURISDICTION FLAGS: EEA member states have varying ages of digital consent ranging from 13 to 16 under GDPR Article 8, affecting when parental consent is required for advertising-related processing. The EU DSA's prohibition on profiling-based advertising targeting minors applies regardless of the Roblox age threshold. California's CPRA imposes restrictions on advertising to consumers under 16. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising partners must be contractually restricted from using data from users under 18 for personalized advertising purposes. Advertising platform agreements should be reviewed to confirm this restriction is operationally implemented at the data transfer level, not merely through policy representation. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether age verification mechanisms are technically sufficient to enforce the 18+ personalized advertising threshold, evaluate whether the consent mechanism for personalized advertising in GDPR jurisdictions meets the standard of freely given, specific, informed, and unambiguous consent, and review advertising partner contracts to confirm downstream enforcement of the under-18 non-personalization requirement.
This provision establishes a platform-wide age gate for personalized advertising set at 18 rather than the COPPA threshold of 13, which represents a more restrictive advertising policy for the 13-17 age cohort and may interact with GDPR consent requirements for users in the EEA who are minors under applicable national law.
This clause establishes that users under 18 on Roblox will not receive personalized advertisements regardless of COPPA or GDPR minimum age thresholds, and that users 18 and older can control personalized ad delivery through Roblox account settings. Where consent is required by applicable law, the policy states consent will be obtained before personalized ads are served.
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