Roblox states it shares your personal data with advertising and analytics companies, who may use tracking technologies to follow your activity on Roblox and potentially on other websites.
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 sharing of identifiers, behavioral data, and device information with third-party advertising partners who may use this data for cross-context behavioral advertising, which constitutes data 'sharing' under CPRA and may trigger opt-out rights for California residents.
Interpretive note: The specific list of advertising and analytics partners is not disclosed in the policy text; the full scope of sharing cannot be assessed from the document alone.
According to the policy, personal data including device identifiers, behavioral data, and usage information may be shared with advertising and analytics partners who use tracking technologies across platforms. California residents have the right to opt out of this sharing by using the 'Do Not Sell or Share My Personal Information' mechanism.
How other platforms handle this
Zoom may share personal data with third-party advertising partners and analytics providers to deliver targeted advertising and measure the effectiveness of advertising campaigns. This may include sharing identifiers, device information, and behavioral data with partners such as advertising networks.
We may share personal information with third-party advertising partners and analytics providers to help us understand how our services are used and to serve relevant advertising. These third parties may use cookies, pixel tags, and similar tracking technologies to collect information about your use ...
We receive some of the data mentioned above from third parties. The below table describes the categories of those third parties. If you connect your Spotify account to a third party application, service or device, we may collect and use information from them. This collection is to make the integrati...
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"We may share your personal information with third-party advertising partners, analytics providers, and business partners to provide you with targeted advertisements and to measure the effectiveness of our advertising campaigns. These partners may use cookies, pixels, and similar tracking technologies to collect information about your use of the Roblox platform and other websites or applications.— Excerpt from Roblox's Roblox Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages CCPA/CPRA, which defines 'sharing' to include disclosures of personal information to third parties for cross-context behavioral advertising even where no monetary consideration is exchanged. California residents have a statutory right to opt out. The provision also engages GDPR Article 6 for EU/EEA users, requiring a lawful basis (typically consent) for sharing with advertising partners. (2) GOVERNANCE EXPOSURE: High. The disclosure that third-party partners may use tracking technologies across other websites and applications indicates cross-context data collection extending beyond the Roblox platform. This practice may require evaluation under CPRA's expanded definition of sensitive personal information and opt-out rights, and under GDPR consent requirements for cookie-based advertising in the EU. (3) JURISDICTION FLAGS: California (CCPA/CPRA opt-out right), EU/EEA (GDPR consent requirements for advertising cookies), UK (UK GDPR and PECR for cookie-based tracking), Brazil (LGPD), and other jurisdictions with data sharing restrictions. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements or data sharing agreements with advertising and analytics partners should specify the permitted purposes for data use, restrict onward transfer, and confirm that partners honor opt-out signals. Where partners are acting as independent controllers (rather than processors), this characterization affects the obligations that flow from the agreement. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain an up-to-date list of all advertising and analytics partners receiving personal data, confirm that contractual protections are in place, and ensure that the opt-out mechanism for California residents is technically effective (i.e., that opt-out signals are passed to all downstream partners). Cookie consent mechanisms for EU/EEA users should be audited to confirm that advertising cookies are not set prior to obtaining valid consent.
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The policy authorizes sharing of identifiers, behavioral data, and device information with third-party advertising partners who may use this data for cross-context behavioral advertising, which constitutes data 'sharing' under CPRA and may trigger opt-out rights for California residents.
According to the policy, personal data including device identifiers, behavioral data, and usage information may be shared with advertising and analytics partners who use tracking technologies across platforms. California residents have the right to opt out of this sharing by using the 'Do Not Sell or Share My Personal Information' mechanism.
ConductAtlas has identified this type of provision across 13 platforms. See the full comparison.
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