Roblox · Roblox Privacy Policy · View original document ↗

Cross-Border Data Transfers

Medium severity Medium confidence Explicitdocumentlanguage Common · 78 of 325 platforms
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Document Record

What it is

Roblox may transfer your personal data to the United States and other countries, which may have different privacy protections than your home country. The policy states that by using Roblox, you agree to these transfers.

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)

The policy asserts consent to cross-border data transfers as a basis for transferring data from jurisdictions such as the EU/EEA to the US; under GDPR, reliance on broad consent embedded in a terms of service or privacy policy for international transfers may not satisfy the requirements of a valid transfer mechanism under Chapter V of GDPR, and this provision may require evaluation against the adequacy framework or Article 46 standard contractual clauses.

Interpretive note: The specific legal transfer mechanism relied upon for EU/EEA-to-US transfers (SCCs, adequacy decision, etc.) is not specified in the reviewed policy text; the legal sufficiency of the consent-based approach for ongoing transfers is subject to GDPR interpretation.

Consumer impact (what this means for users)

Your personal data may be transferred to and stored in the United States or other countries as part of Roblox's operations. For EU/EEA users, applicable law may provide additional protections for such transfers that the policy's broad consent language does not fully address.

How other platforms handle this

OpenAI Medium

OpenAI is based in the United States and the information we collect is governed by U.S. law. If you are accessing our services from outside of the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities in the United States and by tho...

Figma Medium

When we transfer personal information from the European Economic Area, United Kingdom, or Switzerland to countries that have not been found to provide an adequate level of protection under applicable law, we take steps to provide appropriate safeguards, including through the use of Standard Contract...

Ideogram Medium

We may transfer your personal information to countries other than the country in which you live. We transfer personal data from the European Economic Area, United Kingdom, and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level ...

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▸ View Original Clause Language DOCUMENT RECORD
"
Roblox is based in the United States, and your personal information may be transferred to and processed in the United States or other countries where Roblox or its service providers operate. These countries may have data protection laws that differ from the laws of your home country. By using the Roblox platform, you consent to the transfer of your personal information to countries outside your home country, including to the United States.

— Excerpt from Roblox's Roblox Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (international data transfers), which requires either an adequacy decision, standard contractual clauses (SCCs), binding corporate rules, or other Article 46 mechanisms for transfers from the EU/EEA to the US. The provision also engages UK GDPR's transfer requirements and similar provisions under Brazil's LGPD and South Korea's PIPA. Reliance on consent as a transfer mechanism under GDPR is permissible only under limited conditions (Article 49(1)(a)), not as a general ongoing transfer basis. (2) GOVERNANCE EXPOSURE: High for EU/EEA and UK operations. The policy asserts broad consent-based authorization for cross-border transfers embedded in the privacy policy, which may not satisfy GDPR's requirements for a valid transfer mechanism for ongoing transfers. The policy does not specify reliance on SCCs or other Article 46 mechanisms in the text reviewed. (3) JURISDICTION FLAGS: EU/EEA (GDPR Chapter V, enforcement by national DPAs), UK (UK GDPR, ICO enforcement), Brazil (LGPD), South Korea (PIPA), and other jurisdictions with data localization or transfer restrictions. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with service providers receiving EU/EEA personal data must include Module 2 or Module 3 SCCs (or equivalent UK transfer mechanisms) where transfers occur to non-adequate countries. Compliance teams should map all cross-border data flows and confirm appropriate transfer mechanisms are documented and implemented. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm whether Roblox relies on SCCs, an adequacy decision (for US transfers, the EU-US Data Privacy Framework), or another Article 46 mechanism for EU/EEA-to-US transfers, and ensure this is disclosed in the privacy policy. The use of consent as a transfer basis should be evaluated against GDPR Article 49 conditions, which require consent to be specific, informed, and given for a particular transfer.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has enforcement jurisdiction over cross-border data transfer representations made by US-based companies, including compliance with privacy frameworks such as the EU-US Data Privacy Framework.
    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 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011065
Document ID
CA-D-00572
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
65526103181ac7fe55d4543ce0b351c34dc032fe69a8add53e6f30543ae9d94a
Analysis generated
May 12, 2026 05:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy Policy
Record ID: CA-P-011065
Captured: 2026-05-12 05:51:06 UTC
SHA-256: 65526103181ac7fe…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-policy/cross-border-data-transfers/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Roblox's Cross-Border Data Transfers clause do?

The policy asserts consent to cross-border data transfers as a basis for transferring data from jurisdictions such as the EU/EEA to the US; under GDPR, reliance on broad consent embedded in a terms of service or privacy policy for international transfers may not satisfy the requirements of a valid transfer mechanism under Chapter V of GDPR, and this provision may …

How does this clause affect you?

Your personal data may be transferred to and stored in the United States or other countries as part of Roblox's operations. For EU/EEA users, applicable law may provide additional protections for such transfers that the policy's broad consent language does not fully address.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 78 platforms. See the full comparison.

Is ConductAtlas affiliated with Roblox?

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