Roblox states it may show targeted ads to teen users aged 13-17 based on their in-game activity and behavior, though settings are available to adjust these preferences.
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 policy authorizes behavioral advertising directed at users as young as 13, which engages a rapidly evolving set of state-level minor privacy laws; the lawfulness of this practice depends on jurisdiction and applicable regulatory guidance.
Interpretive note: The default opt-in or opt-out state of behavioral advertising for teen accounts is not specified in the policy text, creating interpretive uncertainty about the practical scope of this provision.
Previous version allowed behavioral advertising at age 13; current version delays personalized advertising until age 18, establishing a more restrictive policy for teen users.
View full change record →This new provision explicitly enables behavioral advertising to minors aged 13-17 based on in-platform activity, which is a significant expansion of personalized advertising practices for young users.
View full change record →Teen users aged 13-17 may receive targeted advertisements based on their gameplay activity, content viewed, and in-platform interactions, according to the policy. Both parents and teen users can adjust advertising preferences through Roblox account settings.
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"For users between the ages of 13 and 17, we may show interest-based or targeted advertisements based on their in-platform activity, including games played, content viewed, and interactions with other users. Parents of teen users may adjust advertising preferences through account settings. Teen users may also adjust their own advertising preferences in account settings.— Excerpt from Roblox's Roblox Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages the California Age-Appropriate Design Code (AADC), which restricts profiling and targeted advertising directed at users under 18 in California. Similar statutes are in effect or pending in other states. The FTC and state attorneys general have enforcement roles. COPPA does not directly govern 13-17 users federally, but state laws fill this gap in several jurisdictions. (2) GOVERNANCE EXPOSURE: High. Behavioral advertising targeting users under 18 is an active area of regulatory scrutiny. The policy asserts that opt-out controls are available in account settings, but the default state of advertising preferences for teen accounts is not explicitly stated in the policy text, which creates ambiguity about whether advertising is opt-in or opt-out for this age group. (3) JURISDICTION FLAGS: California (AADC, CCPA/CPRA), Colorado, Texas, Florida, and other states with enacted or pending minor privacy statutes. UK users under 18 are subject to the UK Children's Code. EU/EEA users under 18 may have heightened protections under GDPR depending on member state implementation. (4) CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving behavioral data from teen user segments should be reviewed to confirm that contractual restrictions on data use for profiling minors are in place and that downstream processing complies with applicable minor privacy statutes. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm the default advertising setting for accounts registered with dates of birth indicating the user is between 13 and 17. If behavioral advertising is enabled by default for teen accounts, this may require evaluation under the California AADC and similar statutes. A data protection impact assessment for teen user advertising practices may be warranted.
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The policy authorizes behavioral advertising directed at users as young as 13, which engages a rapidly evolving set of state-level minor privacy laws; the lawfulness of this practice depends on jurisdiction and applicable regulatory guidance.
Teen users aged 13-17 may receive targeted advertisements based on their gameplay activity, content viewed, and in-platform interactions, according to the policy. Both parents and teen users can adjust advertising preferences through Roblox account settings.
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