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
The provision operationalizes biometric data collection by designating separate privacy notices for different collection methods, establishing that users who access these specific features are subject to distinct data handling procedures for facial geometry versus facial movement capture.
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.
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 →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 →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 →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.
How other platforms handle this
"By clicking 'Next', you are indicating that you have read and agree to the TERMS OF USE AND PRIVACY POLICY"
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Location data. Data about your device's location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device's IP address...
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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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The provision operationalizes biometric data collection by designating separate privacy notices for different collection methods, establishing that users who access these specific features are subject to distinct data handling procedures for facial geometry versus facial movement capture.
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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