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The policy states that Roblox may transfer user Personal Information as a business asset in mergers, acquisitions, asset sales, insolvency, bankruptcy, or receivership proceedings, with notification and consent required where law mandates it.
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 reserves the right to transfer Personal Information, including data of users under 13, to a successor entity in corporate transactions, with user notification and consent conditioned on legal requirement rather than as a default practice.
Under this clause, user Personal Information may be transferred to acquiring entities or administrators in corporate transactions as a business asset. The policy conditions notification and consent on legal requirement rather than establishing them as a default procedural obligation.
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"We may hand over rights to access your information, including Personal Information: as part of a merger, acquisition, sale of assets, or similar transaction if information is handed over as a business asset in an insolvency, bankruptcy, or receivership Where required by law, we will notify you and ask you to consent to such sharing.Excerpt from Roblox's Privacy Policy
1. REGULATORY LANDSCAPE: GDPR requires that data subjects be informed of changes to the data controller identity and may require a fresh lawful basis for processing following a business transfer. COPPA imposes specific requirements on the transfer of children's data in business transactions. CCPA and CPRA require disclosure of data sales and transfers and provide opt-out rights in certain circumstances. State AG offices may have jurisdiction over business transfer disclosures under applicable consumer protection laws. 2. GOVERNANCE EXPOSURE: Low to Medium. Business transfer provisions are standard in privacy policies, but the conditional nature of notification and consent ('where required by law') rather than a universal commitment creates variability in user protection depending on jurisdiction. For data of users under 13, COPPA may impose specific requirements on the handling of children's data in business transfers. 3. JURISDICTION FLAGS: GDPR may require data subjects to be notified of controller changes as a transparency obligation under Articles 13-14. California's CCPA/CPRA may treat certain business transfers as sales of personal information triggering opt-out rights. COPPA's treatment of children's data in business transfers may require FTC notification or compliance measures. 4. CONTRACT AND VENDOR IMPLICATIONS: Acquisition due diligence should include assessment of data processing obligations, user consent frameworks, and COPPA compliance commitments that would transfer with the business. Acquirers assume regulatory exposure associated with the transferred data. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the conditional notification framework is operationalized through jurisdiction-specific processes, evaluate whether COPPA requires specific procedures for transferring children's data in a business transaction, and confirm that successor entity data processing agreements are in place before transfer occurs.
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This provision reserves the right to transfer Personal Information, including data of users under 13, to a successor entity in corporate transactions, with user notification and consent conditioned on legal requirement rather than as a default practice.
Under this clause, user Personal Information may be transferred to acquiring entities or administrators in corporate transactions as a business asset. The policy conditions notification and consent on legal requirement rather than establishing them as a default procedural obligation.
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