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
Using 'consent by use' as the legal basis for international data transfers to the US is legally questionable under GDPR — this approach was specifically challenged in Schrems II, and a platform cannot rely on mere service usage as valid GDPR consent for data transfers.
The policy authorizes Roblox to collect a broad range of personal data including identifiers, device information, behavioral and gameplay data, chat logs, and location-related data, and to share this information with advertising, analytics, and business partners for targeted advertising purposes, including for teen users aged 13-17. For users under 13, parental consent is required and parents have rights to access, correct, and delete their child's data, though the practical enforcement of these protections depends on the accuracy of age verification mechanisms. You can submit a privacy data request, including deletion requests, by visiting https://www.roblox.com/my/account or emailing privacy@roblox.com.
How other platforms handle this
If you are located in the European Economic Area, the United Kingdom, or Switzerland, please be aware that we may transfer your personal information to countries outside of these regions, including to the United States, where data protection laws may not provide the same level of protection as those...
You will provide personal information directly to our website in the United States. We may also transfer personal information to our partners and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data prote...
ClickUp is based in the United States and the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same...
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"Roblox 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 information collected through our services may be transferred to, processed, stored, and used in the United States and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those in your country of residence. Your use of our services or provision of any information therefore constitutes your consent to the transfer of your information to the U.S. and to the processing of your data in the U.S. subject to U.S. law.— Excerpt from Roblox's Roblox Privacy Policy
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Using 'consent by use' as the legal basis for international data transfers to the US is legally questionable under GDPR — this approach was specifically challenged in Schrems II, and a platform cannot rely on mere service usage as valid GDPR consent for data transfers.
ConductAtlas has identified this type of provision across 49 platforms. See the full comparison.
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