The policy states that Roblox may collect facial images including selfies from users for the purpose of estimating age, with those images deleted upon completion of the age assurance process.
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 discloses collection of facial images for age estimation purposes, which may constitute biometric data collection under applicable state and national laws including Illinois BIPA, Texas CUBI, Washington My Health MY Data Act, and GDPR's special category data provisions. The stated deletion practice upon process completion does not eliminate the collection itself as a regulatory trigger in jurisdictions with strict biometric data consent requirements.
Interpretive note: Whether the temporary collection of facial images for age estimation constitutes biometric data collection subject to BIPA, CUBI, or GDPR Article 9 depends on technical implementation details and jurisdictional definitions not fully established by this policy text alone.
This clause establishes that Roblox may collect users' facial images for age estimation, with deletion occurring after the process completes. The agreement references a separate Roblox Facial Media Capture Policy for additional detail, which is a distinct document not fully reproduced here.
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"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.— Excerpt from Roblox's Roblox Privacy Policy
REGULATORY LANDSCAPE: Collection of facial images for age estimation may constitute biometric data collection under Illinois BIPA, which requires prior written consent and prohibits profit from biometric data; Texas CUBI; Washington state law; and GDPR Article 9 as biometric data processed for the purpose of uniquely identifying a natural person. The FTC and state Attorneys General in Illinois, Texas, and Washington are relevant enforcement authorities. GDPR supervisory authorities in the EEA are relevant for European users. GOVERNANCE EXPOSURE: High. Even temporary collection of facial images for age estimation triggers consent, notice, and data handling obligations under multiple biometric privacy frameworks regardless of the stated deletion practice. Organizations in Illinois, Texas, and Washington face specific statutory exposure. JURISDICTION FLAGS: Illinois BIPA imposes a private right of action with statutory damages of $1,000 to $5,000 per violation; Texas CUBI is enforced by the state AG. GDPR imposes heightened obligations for biometric data as special category data. The provision's applicability and required consent mechanisms differ materially across these jurisdictions. CONTRACT AND VENDOR IMPLICATIONS: If age assurance is performed by a third-party vendor, data processing agreements must address biometric data handling, consent verification, deletion confirmation, and liability allocation in accordance with applicable state biometric laws and GDPR. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the age assurance process constitutes biometric data collection under applicable definitions in all deployment jurisdictions; ensure that consent mechanisms prior to facial image capture meet jurisdiction-specific requirements; verify that vendor deletion practices are contractually enforceable and auditable; and confirm that the separate Facial Media Capture Policy is consistent with obligations in this provision.
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This provision discloses collection of facial images for age estimation purposes, which may constitute biometric data collection under applicable state and national laws including Illinois BIPA, Texas CUBI, Washington My Health MY Data Act, and GDPR's special category data provisions. The stated deletion practice upon process completion does not eliminate the collection itself as a regulatory trigger in jurisdictions with …
This clause establishes that Roblox may collect users' facial images for age estimation, with deletion occurring after the process completes. The agreement references a separate Roblox Facial Media Capture Policy for additional detail, which is a distinct document not fully reproduced here.
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