The terms disclose that Roblox collects biometric data, including facial geometry, through optional features including age verification, facial media capture, and facial animation tools. Separate privacy notices govern the collection, use, sharing, retention, and destruction of this biometric data.
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 collection of biometric data, including facial geometry, through consumer-facing features triggers state biometric privacy statutes including Illinois BIPA, Texas CUBI, and Washington's biometric data law, as well as GDPR Article 9 special category data obligations for EU users. Separate notices governing retention and destruction schedules are referenced but not reproduced in the main terms.
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 →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 →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 optional facial animation, facial media capture, or age verification features consent to Roblox collecting biometric data including facial geometry. The terms state that separate notices govern how that data is collected, used, shared, retained, and destroyed.
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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
(1) REGULATORY LANDSCAPE: Collection of facial geometry and biometric identifiers engages Illinois BIPA (740 ILCS 14), Texas Capture or Use of Biometric Identifier Act (CUBI), Washington My Health MY Data Act, and California's CCPA biometric …
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The collection of biometric data, including facial geometry, through consumer-facing features triggers state biometric privacy statutes including Illinois BIPA, Texas CUBI, and Washington's biometric data law, as well as GDPR Article 9 special category data obligations for EU users. Separate notices governing retention and destruction schedules are referenced but not reproduced in the main terms.
Users who activate optional facial animation, facial media capture, or age verification features consent to Roblox collecting biometric data including facial geometry. The terms state that separate notices govern how that data is collected, used, shared, retained, and destroyed.
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