Roblox · Roblox Terms of Use · View original document ↗

Advertising to All Users Including Minors

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Roblox recorded 3 documented changes in the last 30 days.
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Document Record

What it is

Roblox now explicitly permits advertisements, both personalized and non-personalized, to be shown to all users on the platform, including children and teenagers.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The provision operationalizes Roblox's commercial content moderation structure by establishing that ad placement extends across the user base without age-based restrictions on ad eligibility, while creating separate delivery mechanisms for personalized versus non-personalized advertising based on user classification.

Interpretive note: The document distinguishes between personalized and non-personalized ads but does not fully specify in the summary language what data is used for personalization or the precise consent mechanism for minor users; the full Privacy Policy and regional appendices govern these details.

Recent Activity

This document changed recently

Medium May 1, 2026

The updated Terms of Use, effective April 30, 2026, restructure how Roblox identifies itself and organizes its governing policies. The agreement now explicitly names Roblox subsidiaries operating in multiple jurisdictions (Japan, Canada, UK, India, Korea, Australia, Netherlands) throughout the terms. New sections addressing advertising integrations and content moderation have been added to the table of contents, suggesting expanded disclosure around ad policies and moderation procedures. According to the change summary, Roblox is providing additional clarity on who can see personalized versus non-personalized ads and clarifying API terms applicable to developers. The full operational implications of these changes require review of the complete updated policy document.

View change record →
High Apr 23, 2026

Roblox removed substantial portions of its Terms of Use, including sections covering dispute resolution, arbitration agreements, and class action waivers, which historically limited user remedies in disputes. The removal of language governing payments, refunds, user accounts, and intellectual property rights creates uncertainty about what protections or obligations currently apply, as replacements have not been provided in the change summary. Users should review the updated full terms when available to understand how disputes will be handled, what account protections exist, and how refunds and payments are governed.

View change record →
Medium Apr 19, 2026

Roblox has restructured its Terms of Use into discrete sections covering user accounts, virtual currency (Robux), payments, intellectual property, online safety, third-party integrations, and dispute resolution. The updated document now explicitly organizes obligations by functional area, making specific rights and requirements easier to locate. The document introduces formal sections on arbitration agreements and class action waivers, meaning disputes will be governed by these procedures as stated in the updated terms.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 7, 2026
First Seen
May 11, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

Children and teenagers using Roblox may now be shown advertisements within the platform, including potentially personalized ads based on their data, which raises questions about the adequacy of consent and parental controls for minor users.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Review the Roblox Privacy and Cookie Policy for options to limit data use for personalized advertising. Log into your Roblox account settings to review and adjust advertising and data preferences, particularly for minor users.

How other platforms handle this

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Strava Medium

We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...

Shein Medium

src="https://trc.taboola.com/1142432/trc/3/json" ... src="https://www.googletagmanager.com/gtag/js?id=DC-15299257" ... src="https://tr.snapchat.com/config/com/af90c7f8-bd28-4988-b1ce-1711aad792f4.js" ... src="https://tr.snapchat.com/config/com/8fbe1595-8c5a-46b1-bbb2-66f3d57debde.js" ... src="https:...

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▸ View Original Clause Language DOCUMENT RECORD
"
We are making changes to our Terms of Use and Privacy Policy to better moderate commercial content in experiences and permit ads to all users on the platform. We added language clarifying who can see personalized and non-personalized ads on Roblox.

— Excerpt from Roblox's Roblox Terms of Use

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision most directly engages COPPA, which restricts the collection and use of personal information from children under 13 for behavioral advertising without verifiable parental consent. The FTC Act's prohibition on unfair or deceptive practices applies to advertising directed at children. The EU/EEA appendix and UK appendix may impose additional restrictions under GDPR, UK GDPR, and the UK Age Appropriate Design Code (Children's Code) regarding profiling and behavioral advertising directed at minors. The DSA (Digital Services Act) may also be relevant for EU/EEA users under the OSA Annex referenced in the document. GOVERNANCE EXPOSURE: High. The explicit expansion of advertising to all users, combined with the distinction between personalized and non-personalized ads, suggests that some users including minors may receive behavioral advertising. If personalized ads for under-13 users involve processing behavioral data, this may require verifiable parental consent under COPPA. The platform's large minor user base amplifies this exposure significantly. JURISDICTION FLAGS: United States (COPPA, FTC Act, California CCPA/CPRA for minors under California law), EU/EEA (GDPR Article 8 on children's consent, DSA restrictions on profiling minors), UK (UK GDPR, Children's Code), and Australia (Privacy Act, with recent amendments strengthening children's privacy protections) all create heightened exposure. Each regional appendix should be assessed for whether it adequately addresses these obligations. CONTRACT AND VENDOR IMPLICATIONS: Advertisers placing ads on Roblox through the Ads Manager or Advertising Integrations Terms should assess their own compliance obligations when advertising reaches minor users. Brand advertisers should review Roblox's advertising standards for child-directed content and ensure their campaigns are consistent with applicable law. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanisms used to distinguish under-13 users from older users and verify that parental consent flows are adequate for any personalized advertising targeting minors. Data mapping updates should identify what behavioral or preference data is used to serve personalized versus non-personalized ads and whether COPPA's verifiable parental consent standard is met for each category.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and has authority over advertising practices directed at children, including behavioral advertising that may involve collection of personal data from minors without adequate parental consent.
    File a complaint →
  • State AG
    State attorneys general, particularly in California, have authority under state consumer protection and children's privacy laws to investigate advertising practices directed at minors.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Terms of Use
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-005117
Document ID
CA-D-00072
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b5e88e6638e4c4af86c865cf8bbbdef0ef2e03366a3773058d9d46e96e83ded0
Analysis generated
May 10, 2026 01:50 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Terms of Use
Record ID: CA-P-005117
Captured: 2026-05-10 01:50:56 UTC
SHA-256: b5e88e6638e4c4af…
URL: https://conductatlas.com/platform/roblox/roblox-terms-of-use/advertising-to-all-users-including-minors/
Accessed: June 29, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's Advertising to All Users Including Minors clause do?

The provision operationalizes Roblox's commercial content moderation structure by establishing that ad placement extends across the user base without age-based restrictions on ad eligibility, while creating separate delivery mechanisms for personalized versus non-personalized advertising based on user classification.

How does this clause affect you?

Children and teenagers using Roblox may now be shown advertisements within the platform, including potentially personalized ads based on their data, which raises questions about the adequacy of consent and parental controls for minor users.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.