The policy states that personalized advertising is disabled for users under 13 by default and is not available to any user under the age of 18, regardless of account settings.
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 hard age threshold of 18 for personalized advertising participation, which the April 2026 update added clarifying language to address. This clause directly governs which user populations are eligible for behavioral or interest-based advertising on the platform and is relevant to both COPPA compliance for under-13 users and broader youth advertising regulatory frameworks.
Under this clause, users under 18 will not receive personalized advertising on Roblox; users aged 13-17 may access certain features unavailable to under-13 users but remain excluded from personalized ad targeting. The agreement establishes this as an automatic account-level setting rather than an opt-out mechanism.
How other platforms handle this
Our Services are not directed to children under 13. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us at privacy@medium.com.
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
To access and use the Services, you must be at least the age of majority in the state, province, or territory where you live or at least 18 years of age. If you are under the age of 13, you may not use the Services and you should not be visiting the Sites or using the Services.
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"If you're under 13 years old, we'll automatically set your account to have stronger privacy settings. While in this privacy mode, some features like personalized advertising and alerts are disabled. When you turn 13, you will be able to enable additional features that are more appropriate for users ages 13 and up (though we won't personalize ads until you're 18).— Excerpt from Roblox's Roblox Privacy Policy
REGULATORY LANDSCAPE: This provision implicates COPPA for users under 13 in the US, which restricts behavioral advertising directed at children; it also engages FTC guidance on advertising to minors and may interact with emerging US state youth privacy laws such as California's Age-Appropriate Design Code (AADC) and similar statutes in other states. The FTC is the primary enforcement authority for COPPA compliance. GOVERNANCE EXPOSURE: Medium. The provision establishes a clear internal age threshold for advertising personalization, which reduces COPPA exposure for under-13 users; however, the distinction between personalized and non-personalized advertising, and what data is collected in either case, may warrant further evaluation under FTC guidance and state AADC requirements. JURISDICTION FLAGS: California's AADC and similar youth-focused digital design laws in Virginia, Texas, and other states may impose obligations beyond the 18-year threshold established here, including data minimization requirements and restrictions on profiling minors even for non-personalized purposes. CONTRACT AND VENDOR IMPLICATIONS: Advertising partners and analytics vendors operating on the platform should be evaluated to confirm that their data processing agreements align with the age-gating commitments stated in this provision. The policy notes that service providers are subject to contractual requirements, but the specific scope of those requirements is not detailed in this document. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the operational implementation of the 18-year advertising threshold is consistently applied across all ad-serving systems, third-party SDKs, and data flows; whether non-personalized advertising served to under-18 users still involves any behavioral data collection; and whether the distinction between personalized and non-personalized advertising is documented in internal data mapping.
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This provision establishes a hard age threshold of 18 for personalized advertising participation, which the April 2026 update added clarifying language to address. This clause directly governs which user populations are eligible for behavioral or interest-based advertising on the platform and is relevant to both COPPA compliance for under-13 users and broader youth advertising regulatory frameworks.
Under this clause, users under 18 will not receive personalized advertising on Roblox; users aged 13-17 may access certain features unavailable to under-13 users but remain excluded from personalized ad targeting. The agreement establishes this as an automatic account-level setting rather than an opt-out mechanism.
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