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 incorporate previously separate AI tool disclosures and advertising policies directly into the main user and creator agreement sections. The document now includes regional appendices addressing compliance requirements for the EU/EEA, UK, Australia, China, Japan, and Vietnam, which may apply different terms or restrictions based on your location. The restructuring removes the standalone change summary that previously explained these updates in plain language, relocating that information throughout the terms document itself.
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.
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NIM container releases that collect data, collect it for the following purposes: (a) to properly configure and optimize products for use with Software; and (b) to improve NVIDIA products and services.
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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 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 …
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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.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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