For players under 13, Roblox states it collects limited information and requires parent permission before collecting more. Parents can ask Roblox to show them, fix, or delete their child's 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
COPPA requires verifiable parental consent before collecting personal data from children under 13; the adequacy of Roblox's consent and age-verification mechanisms directly affects the legal compliance of data collection from its youngest users.
Interpretive note: The operational adequacy of the age-gating and parental consent verification mechanism cannot be assessed from the policy text alone; enforcement depends on technical implementation.
Previous version stated only necessary information was collected with parental consent; current version now explicitly includes persistent identifiers (IP address, device identifiers) collected from users under 13 without mentioning parental consent requirement.
View full change record →Added explicit mention of parental consent requirements, email address collection, and parent rights to review/correct/delete child data; removed incomplete excerpt text.
View full change record →The policy states that Roblox limits data collection for under-13 users to username, password, date of birth, and optionally an email address, and asserts that additional data collection requires parental consent. Parents who want to review or delete their child's data can do so by contacting privacy@roblox.com.
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"For users under 13, we collect only the information necessary to create and maintain their Roblox account, including a username, password, date of birth, and, if provided by the parent or user, an email address. We obtain verifiable parental consent before collecting additional personal information from users under 13. Parents can review, correct, or request deletion of their child's personal information by contacting us at privacy@roblox.com.— Excerpt from Roblox's Roblox Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly implicates COPPA, enforced by the FTC, which requires verifiable parental consent before collecting, using, or disclosing personal information from children under 13. The FTC has enforcement authority and has brought significant actions against platforms with large minor user bases. The provision also engages state-level children's privacy statutes where applicable. (2) GOVERNANCE EXPOSURE: High. The accuracy of age-gating at account creation is the critical operational question. If users under 13 can create accounts without triggering the parental consent workflow (e.g., by entering a false date of birth), the COPPA protections asserted in this provision may not be operationally implemented, creating FTC enforcement exposure. (3) JURISDICTION FLAGS: United States (federal COPPA), California (CCPA/CPRA and California Age-Appropriate Design Code), and states with minor-specific privacy statutes including Texas and Florida. The UK Children's Code (Age Appropriate Design Code) creates parallel obligations for UK users under 18. (4) CONTRACT AND VENDOR IMPLICATIONS: Any third-party service provider or analytics/advertising partner that receives data from Roblox must be contractually restricted from using data associated with under-13 accounts for advertising or profiling. Data processing agreements with these vendors should be reviewed to confirm appropriate restrictions are in place. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the technical implementation of the age-gate at account registration to confirm that users who enter a date of birth indicating they are under 13 are routed through the parental consent workflow rather than the standard registration flow. The parental consent verification method should be assessed for adequacy under FTC COPPA guidance.
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COPPA requires verifiable parental consent before collecting personal data from children under 13; the adequacy of Roblox's consent and age-verification mechanisms directly affects the legal compliance of data collection from its youngest users.
The policy states that Roblox limits data collection for under-13 users to username, password, date of birth, and optionally an email address, and asserts that additional data collection requires parental consent. Parents who want to review or delete their child's data can do so by contacting privacy@roblox.com.
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