The policy states that Roblox may collect facial images, including selfies, to estimate a user's age, and that such images are deleted after the age assurance process is completed. Additional detail is provided in a separate Roblox Facial Media Capture Policy.
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
This provision establishes a biometric data collection practice for age estimation purposes, which may require evaluation under state biometric privacy laws including Illinois BIPA, Texas CUBI, and Washington's My Health My Data Act, as well as GDPR's requirements for processing biometric data as a special category under Article 9.
Interpretive note: Whether facial images used for age estimation constitute biometric data subject to BIPA or GDPR Article 9 depends on the specific processing methodology and whether unique biometric identifiers are extracted, which is not fully described in this document.
Added reference to separate Roblox Facial Media Capture Policy for additional transparency.
View full change record →This new biometric data collection practice represents a significant privacy expansion, as Roblox now explicitly collects and processes facial images, though with stated deletion after verification.
View full change record →This clause establishes that Roblox may collect and process facial images from users for age verification purposes, with the policy stating that images are deleted once the process is complete. The scope of consent requirements and the full data lifecycle for age assurance processing are described in a separate linked policy document.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
to object to profiling activities based on our own legitimate interests
"To assess user ages, Roblox may collect information about you, including images such as a selfie, to perform age assurance. Information collected to assess user ages, such as images taken to perform facial age estimation, is deleted once the age assurance process is complete. You can learn more about Roblox's practices in the Roblox Facial Media Capture Policy.Excerpt from Roblox's Privacy Policy
1.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision establishes a biometric data collection practice for age estimation purposes, which may require evaluation under state biometric privacy laws including Illinois BIPA, Texas CUBI, and Washington's My Health My Data Act, as well as GDPR's requirements for processing biometric data as a special category under Article 9.
This clause establishes that Roblox may collect and process facial images from users for age verification purposes, with the policy stating that images are deleted once the process is complete. The scope of consent requirements and the full data lifecycle for age assurance processing are described in a separate linked policy document.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.