Roblox · Roblox Privacy Policy · View original document ↗

COPPA Compliance and Children's Data Practices

High severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Children under 13 can use Roblox with a username, password, and birthdate, plus an optional gender. Roblox collects persistent identifiers like IP addresses for internal operations and states it does not use this data for behavioral advertising.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes the data collection floor for Roblox's youngest users and the legal framework under which Roblox claims COPPA compliance, which is one of the most actively enforced areas of US privacy law for platforms with minor users.

Consumer impact (what this means for users)

Children under 13 on Roblox have their data collection limited to account setup information and persistent identifiers for internal operations only. Parents have the right to review, delete, or restrict further collection of their child's personal information by submitting a request through the Roblox Customer Support Form.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Parents or guardians should visit roblox.com/support and submit a Customer Support Form to request review, deletion, or restriction of their child's personal information. If under 13, the child should not submit the form independently.

How other platforms handle this

McDonald's Medium

Our online services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible.

T-Mobile Medium

Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected personal information from a child under the age of 13 without parental consent, we wil...

ElevenLabs Medium

Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information.

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▸ View Original Clause Language DOCUMENT RECORD
"
If you're under 13 years old and create an account, we ask for some information (which is non-personal information, as defined by COPPA) to let you use Roblox. We'll collect: your username (required). We need this to create your account and run the Roblox Service. We don't use your username to identify you outside of Roblox; your password (required). We need this to log you in to your account and to run the Roblox Service; your date of birth (required). We'll use this information to make sure your account has certain default settings intended for your age; your gender (optional). We will use this information to customize your experience.

— Excerpt from Roblox's Roblox Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC. COPPA requires verifiable parental consent before collecting personal information from children under 13, with limited exceptions for internal operations. Roblox's reliance on the internal operations exception for persistent identifier collection is a standard but scrutinized approach. The FTC has historically taken enforcement action against platforms that allowed third-party access to children's data even where internal-operations exceptions were claimed. The policy's assertion that persistent identifiers are used only for enumerated internal operations is a key compliance claim that requires operational verification. GOVERNANCE EXPOSURE: High. Roblox's large under-13 user base makes COPPA compliance a primary enforcement risk. The policy asserts that contractual requirements and technical measures prevent misuse of persistent identifiers, but the adequacy of these controls is not described in detail. Any gap between the policy's assertions and operational implementation could constitute a COPPA violation with significant civil penalty exposure. JURISDICTION FLAGS: United States (COPPA, FTC enforcement). State-level children's privacy laws in California (AADC-equivalent protections under CPRA), Utah, and other states may impose additional obligations for minor users that exceed COPPA's baseline. Internationally, GDPR Article 8 and UK GDPR impose more stringent parental consent requirements for users under 16 (or lower national age thresholds). CONTRACT AND VENDOR IMPLICATIONS: Service providers processing persistent identifiers from users under 13 must be bound by contractual requirements sufficient to meet COPPA's operator-agent standard. Vendor contracts should be reviewed to confirm they prohibit secondary use of children's data, require deletion upon request, and include audit rights. Standard vendor agreements may not include these provisions without specific COPPA addenda. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the list of service providers with access to persistent identifiers from under-13 users to confirm contractual compliance. The parental consent and notification flows, including the optional parent email collection and the 24-hour deletion window if linking is not completed, should be tested for operational accuracy. The retention policy for children's data, including the two-year post-deletion safety retention period, should be evaluated for consistency with COPPA's data minimization requirements.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC is the primary enforcement authority for COPPA and has brought multiple enforcement actions against online platforms for violations of children's privacy rules.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009157
Document ID
CA-D-00572
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c9ff151f304301a790e0c1f0051afe92cf3710fd496fd06cadf0d0b3b6f49840
Analysis generated
May 10, 2026 15:15 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy Policy
Record ID: CA-P-009157
Captured: 2026-05-10 15:15:29 UTC
SHA-256: c9ff151f304301a7…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-policy/coppa-compliance-and-childrens-data-practices/
Accessed: May 14, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's COPPA Compliance and Children's Data Practices clause do?

This provision establishes the data collection floor for Roblox's youngest users and the legal framework under which Roblox claims COPPA compliance, which is one of the most actively enforced areas of US privacy law for platforms with minor users.

How does this clause affect you?

Children under 13 on Roblox have their data collection limited to account setup information and persistent identifiers for internal operations only. Parents have the right to review, delete, or restrict further collection of their child's personal information by submitting a request through the Roblox Customer Support Form.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.