Roblox can collect your facial geometry and biometric data if you use camera-based features like facial animations, age verification, or certain chat features, with data handling governed by separate privacy notices.
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
Biometric data is among the most sensitive categories of personal information, and state laws such as Illinois BIPA impose strict consent, retention, and destruction requirements that carry significant statutory damages for violations.
Interpretive note: The core terms reference separate privacy notices for biometric data handling details; the full scope of data sharing, retention periods, and destruction procedures is not disclosed in the Terms of Use itself, creating interpretive uncertainty about compliance with state biometric privacy statutes.
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Users who activate facial capture, animation, or age verification features consent to Roblox collecting, using, sharing, retaining, and destroying their facial geometry and biometric data according to terms set out in separate privacy notices that users must independently review.
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"The Facial Media Capture Privacy Notice applies to any User who uses additional features on Roblox that require the use of one's camera or the uploading of files that contain an individual's facial geometry (including age verification) and explains how Roblox collects, uses, shares, retains, and destroys your Biometric Data when you use the Services. The Facial Animation Privacy Notice applies to any User who activates and enables tools on the Service, including Animation Capture-Face or Chat, that capture and animate facial movements and explains how Roblox collects, uses, shares, retains, and destroys the data collected when you use the Services.— Excerpt from Roblox's Roblox Terms of Use
REGULATORY LANDSCAPE: Biometric data collection is governed by Illinois BIPA (which requires informed written consent, a publicly available retention policy, and prohibits sale of biometric data), Texas CUBI, Washington My Health MY Data Act, and similar state statutes. GDPR Article 9 classifies biometric data as a special category requiring explicit consent from EU/EEA users. COPPA is relevant if facial capture features are accessible to under-13 users. The FTC has taken enforcement action against companies that collect biometric data without adequate disclosure or consent. The specific inclusion of age verification as a use case for facial geometry collection adds a dimension of identity data processing that may engage additional state and federal requirements. GOVERNANCE EXPOSURE: High. The collection of biometric data, including facial geometry and animation capture, creates significant statutory liability exposure under BIPA (statutory damages of $1,000 to $5,000 per violation per person) and equivalent state statutes. The delegation of detailed terms to separate privacy notices (Facial Media Capture Privacy Notice, Facial Animation Privacy Notice) means the core Terms of Use do not fully disclose the retention schedule, destruction timeline, or third-party sharing scope, which itself may create a disclosure adequacy issue under some state laws. JURISDICTION FLAGS: Illinois (BIPA), Texas (CUBI), Washington, and the EU/EEA (GDPR Article 9) create the highest exposure. Minor users in any of these jurisdictions who use facial capture features add a further layer of parental consent requirements. The use of facial geometry for age verification creates a specific data minimization and proportionality question under GDPR and UK GDPR. CONTRACT AND VENDOR IMPLICATIONS: Any third-party vendors processing biometric data on behalf of Roblox (e.g., age verification service providers) must be assessed under applicable state biometric privacy laws. Data processing agreements should specify retention and destruction schedules consistent with BIPA and similar statutes. If facial geometry data is shared with third parties for age verification, those data flows require specific contractual safeguards. COMPLIANCE CONSIDERATIONS: Legal teams should audit the Facial Media Capture Privacy Notice and Facial Animation Privacy Notice against BIPA and applicable state statutes to confirm adequacy of consent language, retention schedules, and destruction procedures. A data mapping exercise should confirm whether facial geometry data is processed separately from general account data and whether separate consent workflows are deployed before any biometric feature is activated, particularly for minor users.
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Biometric data is among the most sensitive categories of personal information, and state laws such as Illinois BIPA impose strict consent, retention, and destruction requirements that carry significant statutory damages for violations.
Users who activate facial capture, animation, or age verification features consent to Roblox collecting, using, sharing, retaining, and destroying their facial geometry and biometric data according to terms set out in separate privacy notices that users must independently review.
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