The policy states that Roblox collects IP addresses and unique device identifiers from users under 13 for specified internal operations including contextual advertising frequency capping, authentication, and security, without requiring separate parental consent for these identifiers under the COPPA internal operations exception.
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 invokes the COPPA internal operations exception to justify collecting persistent identifiers from children without separate verifiable parental consent. The scope of permitted uses, including contextual advertising frequency capping, may warrant evaluation against FTC guidance on what constitutes permissible internal operations under COPPA.
Interpretive note: Whether contextual advertising frequency capping falls within the permissible scope of the COPPA internal operations exception is subject to FTC interpretive guidance and may depend on operational implementation details not fully disclosed in this document.
Renamed to COPPA-restricted version with more detailed enumeration of specific internal operations and added emphasis on contextual advertising and compliance measures.
View full change record →This clause establishes that children's IP addresses and device identifiers are collected upon account creation and may be used for contextual advertising frequency management in addition to technical operations. The agreement states that contractual and technical measures are implemented to limit use of these identifiers to the listed purposes.
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"When children sign up for Roblox, we also collect certain types of personal information called persistent identifiers for internal operations and to provide you and other users with Services. Persistent identifiers are data like IP Address and unique device identifiers that are required for you to be able to connect your device to Roblox. Persistent identifiers can be used to recognize you, your device, or your household device. Roblox collects persistent identifiers and the information we ask you for when you sign up for the following internal operations: Maintaining or analyzing the functioning of Roblox; Performing network communications; Authenticating users of, or personalizing the content on, Roblox; Serving contextual advertising, including capping the frequency of ads; Protecting the security or integrity of Roblox; Ensuring legal or regulatory compliance.Excerpt from Roblox's Privacy Policy
REGULATORY LANDSCAPE: This provision directly implicates COPPA, enforced by the FTC, which permits collection of persistent identifiers from children under 13 for internal operations without verifiable parental consent, provided those identifiers are not used for …
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This provision invokes the COPPA internal operations exception to justify collecting persistent identifiers from children without separate verifiable parental consent. The scope of permitted uses, including contextual advertising frequency capping, may warrant evaluation against FTC guidance on what constitutes permissible internal operations under COPPA.
This clause establishes that children's IP addresses and device identifiers are collected upon account creation and may be used for contextual advertising frequency management in addition to technical operations. The agreement states that contractual and technical measures are implemented to limit use of these identifiers to the listed purposes.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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