Third-Party Data Sharing for Advertising and Analytics

What it is

Roblox shares data, including persistent identifiers like IP addresses and device IDs, with third-party service providers to run its platform and advertising systems. For users 13 and older, this can include sharing with advertising and analytics partners.

Why it matters (compliance & governance perspective)

The scope of data sharing with advertising and analytics vendors determines how broadly your behavioral and device data flows beyond Roblox's own systems, which has direct implications for privacy and targeted advertising.

Consumer impact (what this means for users)

For users aged 13 and older, Roblox shares device and behavioral data with advertising and analytics partners, which means your usage patterns and device identifiers may be combined with data from other sources by those third parties. Users can exercise opt-out or data deletion rights through the Roblox support form, and California residents have additional rights under the CCPA and CPRA.

What you can do

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Third-party data sharing with advertising and analytics vendors engages the FTC's unfair and deceptive practices authority, CCPA and CPRA's opt-out-of-sale and sharing provisions, GDPR's requirements for data processing agreements and adequacy of transfers, and COPPA's restrictions on sharing children's data with third parties. The policy characterizes advertising and analytics vendors as service providers, but if those vendors use data for their own purposes, they may qualify as third parties under CCPA, triggering opt-out obligations. GOVERNANCE EXPOSURE: High for users in California and EU; medium for general US users. The characterization of advertising technology vendors as service providers versus third parties under CCPA is a frequently contested area. If vendors engage in cross-context behavioral advertising using Roblox data, CPRA's opt-out-of-sharing provisions are likely triggered regardless of contractual characterization. JURISDICTION FLAGS: California (CCPA and CPRA, opt-out of sale and sharing), EU and EEA (GDPR data processing agreements and Standard Contractual Clauses for international transfers), UK (UK GDPR), Brazil (LGPD), and any US state with comprehensive privacy legislation. The policy's reference to a US State Privacy Policy Addendum indicates awareness of state-level variation but the specific opt-out mechanisms available to users should be confirmed operationally. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics vendor contracts should be reviewed to confirm they meet data processor standards under GDPR, include data processing addenda meeting CCPA service provider requirements, and prohibit vendors from using Roblox user data for their own commercial purposes. International data transfer mechanisms (Standard Contractual Clauses) should be confirmed for EU and UK data flows to non-adequate countries. COMPLIANCE CONSIDERATIONS: Compliance teams should maintain an updated data map of all advertising and analytics vendors receiving Roblox user data, categorized by data type, user age group, and jurisdiction. The policy's opt-out mechanisms should be tested for accessibility and confirmed as operationally effective. Quarterly vendor assessments should confirm compliance with contractual restrictions on data use.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Age-Tiered Advertising Restrictions high
• Facial Age Estimation Data Collection high
• Voice Data Collection for Social Features medium
• COPPA Compliance and Children's Data Practices high
• Data Retention Post-Account Deletion medium
• Law Enforcement and Government Authority Data Sharing medium

Related Analysis

• Meta Removed 438 Sentences From Its Privacy Policy. Here Is What Disappeared.

  ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.

• 23andMe Is Bankrupt. What Happens to Your DNA Now?

  Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.