If you use Roblox's facial animation, age verification, or camera-based features, Roblox collects and processes your biometric data including facial geometry.
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 designates a separate privacy framework to address biometric data practices distinct from the main Terms of Use, establishing procedural requirements for how facial biometric information is processed across specific service features.
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 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 →The updated terms reorganize and clarify existing policies rather than imposing new restrictions. Roblox consolidated AI-related terms from supplemental documents into the main Terms of Use, added clarifying language about how creator content may be used in marketing and advertising, expanded disclosures about ad personalization and targeting practices, and provided additional detail on moderation procedures and group/community owner responsibilities. Practically, users and creators will find AI feature terms more prominently disclosed in the main agreement rather than in supplemental annexes, and the platform provides expanded transparency around advertiser eligibility and how ads are targeted based on personalization preferences.
View change record →Users who enable facial animation or age verification features consent to the collection of biometric information, which carries heightened privacy risks and is subject to strict regulation in several U.S. states including Illinois, Texas, and Washington.
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"Facial Media Capture Privacy Notice. 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.— Excerpt from Roblox's Roblox Terms of Use
Biometric data collection triggers obligations under Illinois BIPA, Texas CUBI, and Washington's Biometric Privacy Law, as well as GDPR Article 9 special category data protections for EU/EEA users; compliance teams should verify that consent mechanisms, retention schedules, and deletion procedures meet all applicable biometric privacy standards.
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The provision designates a separate privacy framework to address biometric data practices distinct from the main Terms of Use, establishing procedural requirements for how facial biometric information is processed across specific service features.
Users who enable facial animation or age verification features consent to the collection of biometric information, which carries heightened privacy risks and is subject to strict regulation in several U.S. states including Illinois, Texas, and Washington.
ConductAtlas has identified this type of provision across 18 platforms. See the full comparison.
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