Roblox does not show personalized ads to anyone under 18, and children under 13 only see contextual ads (ads not based on their personal data). Users between 13 and 17 may see non-personalized ads.
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 creates a tiered feature access model tied to user age, with privacy restrictions automatically enforced for younger users and progressively relaxed upon age milestones. This structure operationalizes compliance with age-based advertising restrictions while preserving feature availability for older user cohorts.
Removal of this provision eliminates the promise that users under 18 will not receive personalized ads, which represents a significant relaxation of privacy protections for minors given the new behavioral advertising provision for ages 13-17.
View full change record →Users under 18 are protected from personalized advertising based on their behavioral or personal data, which limits the extent to which their data is used for targeted commercial purposes while they are minors. However, users 13 and older may still see non-personalized ads, and the data collected for contextual advertising purposes is still processed by third-party systems.
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"If you're under 13 years old, we'll automatically set your account to have stronger privacy settings. While in this privacy mode, some features like personalized advertising and alerts are disabled. When you turn 13, you will be able to enable additional features that are more appropriate for users ages 13 and up (though we won't personalize ads until you're 18).— Excerpt from Roblox's Roblox Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages COPPA, which prohibits behavioral advertising to children under 13 without verifiable parental consent. The FTC enforces COPPA and has published guidance stating that behavioral advertising constitutes a use of personal information requiring disclosure and consent. For users 13 to 17, the provision also engages GDPR Article 8 (consent of children) and various US state laws including California's CCPA and CPRA, which provide specific protections for minors' data. The assertion that non-personalized ads are permissible for 13-to-17-year-olds without additional consent may require evaluation under applicable state law. GOVERNANCE EXPOSURE: High. The advertising framework for minors is one of the highest-risk areas in the document given Roblox's large and well-documented minor user base. The policy asserts a clear age-tiered structure, but the operational implementation of age verification, the contractual obligations imposed on advertising partners, and the definition of 'non-personalized' advertising all require close governance review. Misclassification of minor users or gaps in partner controls could create significant regulatory exposure. JURISDICTION FLAGS: United States (COPPA, FTC enforcement), California (CPRA minor provisions), EU and EEA (GDPR Article 8), UK (UK GDPR), Brazil (LGPD). In the EU, consent for data processing for users under 16 (or the applicable national age, which may be lower in some member states) must come from a parent or guardian, which may be more restrictive than Roblox's 13-year threshold. CONTRACT AND VENDOR IMPLICATIONS: Advertising partner contracts must contractually prohibit personalized advertising to users under 18 and must include controls sufficient to enforce the contextual-only restriction for under-13 users. Due diligence on advertising technology vendors should confirm that age signals are passed correctly and that no user-level behavioral targeting occurs for minors. Standard commercial data processing agreements may not be sufficient without specific minor-protection addenda. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the technical implementation of the age-tiered advertising system to confirm that age signals are reliably transmitted to all advertising and analytics partners. A review of consent flows for users who turn 13 or 18 on the platform should confirm that no retroactive behavioral data is used for advertising without appropriate disclosure. State AG offices in California and other COPPA-active states represent heightened enforcement risk.
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The clause creates a tiered feature access model tied to user age, with privacy restrictions automatically enforced for younger users and progressively relaxed upon age milestones. This structure operationalizes compliance with age-based advertising restrictions while preserving feature availability for older user cohorts.
Users under 18 are protected from personalized advertising based on their behavioral or personal data, which limits the extent to which their data is used for targeted commercial purposes while they are minors. However, users 13 and older may still see non-personalized ads, and the data collected for contextual advertising purposes is still processed by third-party systems.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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