Roblox Privacy and Cookie Policy

Legal Rights & Agreement Rules · Context

This Privacy and Cookie Policy states a November 1, 2026 effective date and announces three changes

The page says it is "updating" the Roblox Privacy and Cookie Policy "effective November 1, 2026". It summarizes three changes: added language on regional variation in access to certain features, added information about data collection from researchers, and added language on practices for sharing information with authorities. The page points to links for the upcoming changes and for the full Privacy Policy, but the text of those linked documents is not part of the supplied source, so what they add beyond this summary is not established here.

Supporting quotations

Effective Date: November 1, 2026

effective November 1, 2026

We added language describing regional variation for access to certain features.

We added information about data collection from researchers.

We added language describing our practices for sharing information with authorities.

Click here to review the upcoming changes.

You can also find the full Privacy Policy

Qualifications & exceptions

• The effective date stated is November 1, 2026; the document itself does not say whether the previous text stays in force until then.
• The change list is a "high-level summary" only.

Not stated here

• What the linked "upcoming changes" article and full Privacy Policy attachment say is not in the supplied source.
• Whether the summary of changes lists every change is not stated.

Legal Rights & Agreement Rules · Context

The policy is for people who make or play games on Roblox, and for parents of under-13s

The policy says it is for anyone who makes or plays games in Roblox experiences, whatever their age and wherever they live. It is also for parents or guardians of users under 13 years old. It covers "the Roblox Services".

Supporting quotations

If you make or play games in Roblox experiences, this Privacy Policy is for you, whatever your age and wherever you live. It’s also for parents or guardians of users under 13 years old. This Policy covers the Roblox Services.

Qualifications & exceptions

• Applies to people who make or play games in Roblox experiences.
• Parents or guardians are addressed only in respect of users under 13.

Not stated here

• "Roblox Services" is defined in a later definition; see the definitions card.

Legal Rights & Agreement Rules · Restriction or exception

The policy covers Roblox websites, apps, Player and Studio, but stops when you leave Roblox

Using Roblox, for this policy, includes roblox.com websites, the mobile, virtual reality and console apps, the Roblox Player and Roblox Studio, and other Roblox features described in the policy. When you leave Roblox's services the policy no longer applies. Roblox says it is not responsible for what you see on other websites or apps or for their privacy policies, even if you reached them through a link from Roblox, and that it may show a message that you are leaving Roblox.

Supporting quotations

Using Roblox includes using:

websites with a roblox.com address

our mobile, virtual reality and console apps

the Roblox Player and the Roblox Studio

Other Roblox features described in this policy

But if you leave our services, this Privacy Policy no longer applies. We’re not responsible for what you see on other websites or apps or for their privacy policies, even if you’ve linked to them from our website or app.

we may show you a message telling you that you’re leaving Roblox

Qualifications & exceptions

• Roblox "may" show a leaving-Roblox message; it does not promise to.
• Applies to other sites and apps even where linked from Roblox.

Not stated here

• What privacy terms apply on sites or apps Roblox links to is not stated; the text of any linked policies is not supplied here.

Legal Rights & Agreement Rules · Restriction or exception

Location-specific rules in Section 7 override the general Sections 1-5

The policy says that if the information in Sections 1-5 conflicts with the location-specific information in Section 7, Section 7 prevails. It also says that depending on where you live you may have different rights or choices for managing your Personal Information, which the policy describes later. A general statement elsewhere in Sections 1-5 should therefore be read as subject to Section 7 for users in the places Section 7 covers.

Supporting quotations

In the event of a conflict between the information in Sections 1-5 of this Policy and the location-specific information in Section 7, the information in Section 7 shall prevail.

Depending on where you live, you may have different rights or choices for managing your Personal Information, which this Policy will describe later on.

Qualifications & exceptions

• Applies only where there is a conflict between Sections 1-5 and Section 7.
• Rights and choices vary by where you live.

Not stated here

• Which locations Section 7 covers and what it says are shown in the Section 7 packets of this analysis, not here.

Cross-references

• qualifies (model-proposed): EEA/UK/Swiss list: no training on EEA private server voice chat; other voice training only with consent — The conflict rule makes the location-specific Section 7 statements prevail over the general sections where they conflict, which bears on how the EEA/UK/Swiss audio statement relates to the general audio statement.

Legal Rights & Agreement Rules · Context

The policy describes your rights and how Roblox collects, records, organizes, stores and shares information

The policy says it describes your rights regarding your Personal Information and explains that you can control what happens to information that can identify you, such as your name, where you live and your email address. It says it will explain when and how Roblox uses information about you, including how it collects, records, organizes, stores and shares it.

Supporting quotations

This policy describes the rights you have regarding your Personal Information. It explains that you can control what happens to the information that can identify you - like your name, where you live and your email address.

we’ll also tell you when and how we use your information about you – including how we collect, record, organize, store and share it.

Qualifications & exceptions

• Introductory description; the operative detail is in the later sections.

Not stated here

• The extent of the control the policy gives over each type of information is set in the later sections.

Legal Rights & Agreement Rules · Procedure

Contact Roblox about Personal Information by form, phone, post or email; under-13s need a parent

Roblox says you can reach it by submitting a question through its Customer Support Form; if you are under 13 a parent or guardian should fill out the form. For the US it lists a phone number, a postal address for the Roblox Privacy Manager and a privacy email address.

Supporting quotations

To reach us with questions or requests regarding your Personal Information, our information about how to contact us is included below.

If you’re under 13 years old, please have your parent or guardian fill out the form.

US: Phone: (888) 858 - BLOX Write to us at: Roblox Corporation Attn: Roblox Privacy Manager Address: 3150 S. Delaware St. San Mateo, California, 94403

Qualifications & exceptions

• If you are under 13, the parent or guardian is asked to fill out the Customer Support Form.
• Postal, phone and email contact details are listed for the US.

Not stated here

• Response times are not stated here.

Legal Rights & Agreement Rules · Procedure

EEA, UK, Swiss and Brazil users have named representatives and data protection officers

For users in the European Economic Area, the United Kingdom or Switzerland, Roblox names a representative under Articles 27 EU and UK GDPR, with separate listed addresses for the EEA and the UK. It also names its data protection officer in the EU under Art. 37 GDPR and lists an address and email for that officer. For Brazil it gives an email address for its Brazilian Data Protection Officer.

Supporting quotations

EEA, UK or Switzerland: If you’re in the European Economic Area (EEA), the United Kingdom, or Switzerland

Our representative according to Articles 27 EU and UK GDPR in the European Union

UK: DP Data Protection Services UK Ltd.

Our data protection officer in the EU according to Art. 37 GDPR can be reached via: DP Dock DPO Services GmbH

Roblox

Grüffkamp 10 24159 Kiel, Germany roblox@dp-officer.com

If you’re in Brazil, contact our Brazilian Data Protection Officer by emailing

Qualifications & exceptions

• Representative and DPO details apply to the listed regions.
• The EU DPO is described as "according to Art. 37 GDPR".

Not stated here

• Which of these contacts handles which request is not specified.

Legal Rights & Agreement Rules · Context

Korea and US state privacy rights are in separate addenda not supplied here

The policy sends users in Korea to a Privacy Policy Addendum for Users in Republic of Korea. For the United States it says additional rules may apply depending on the state you live in, and sends readers to the US State Privacy Policy Addendum to learn about rights under US state laws. The text of those addenda is not part of this source.

Supporting quotations

If you’re in Korea, more information is located in the Privacy Policy Addendum for Users in Republic of Korea

If you’re in the United States, additional rules may apply depending on the state you live in.

To learn more about the rights available to you under US state laws please visit the US State Privacy Policy Addendum

Qualifications & exceptions

• Korea: more information is in the Korea addendum.
• US: additional rules "may" apply depending on the state.

Not stated here

• What the Korea addendum and the US State Privacy Policy Addendum provide is not supplied in this source.

Cross-references

• refers to (model-proposed): US and Korea residents are pointed to separate addenda that are not supplied here — The general contact section and the location section both point to the same US State and Korea addenda, whose text is not supplied.

Legal Rights & Agreement Rules · Context

Defined terms: Children are under 13, Minors are under the legal age of majority, and Service is broad

The policy defines "Children" as users under 13. "Minor" means a user under the legal age of majority in their jurisdiction or state of residence, so the minor line varies by place while the child line is fixed at 13. "Personal Information" means information relating to an identifiable natural person, directly or indirectly, including by a name, identification number, location data or online identifier. "Processing" means any operation on Personal Information, including collecting, recording, organizing, structuring, storing, adapting or disclosing or otherwise using it. "Platform" is the Roblox platform and "Policy" is this Roblox Privacy Policy. "Service" means any service or application Roblox offers, including the roblox.com websites, mobile, virtual reality and console apps, Roblox Player, Roblox Studio and other websites, products, software, applications, content, data feeds and services on which an authorized link to this policy is posted.

Supporting quotations

“Children” or “Child” means any user under the age of 13

“Minor” or “minor user” means a user of the Services who is under the legal age of majority in their jurisdiction or state of residence

“Personal Information” means any information relating to a natural person who can be identified, directly or indirectly

“Processing” means any operation which is performed on Personal Information

“Platform” means our Roblox platform

“Privacy Policy” or “Policy” means this Roblox Privacy Policy

“Service” means any service or application offered by Roblox

Qualifications & exceptions

• Child = under 13; Minor = under the age of majority where the user lives.
• "Service" covers other products where an authorized link to this policy is posted.

Not stated here

• The legal age of majority in each place is not stated.
• The text of any linked document is not supplied here, so the card cannot say what it adds to these definitions.

Legal Rights & Agreement Rules · Context

"Service" means any Roblox service or application, including sites, apps, Player and Studio that link this policy

The policy defines "Service" as any service or application offered by Roblox, such as letting users develop Platform experiences, connect with others and use content created by them and other users. It includes roblox.com websites, the mobile, virtual reality and console apps, the Roblox Player, Roblox Studio, and other websites, products, software, applications, content, data feeds and services on which an authorized link to this Policy is posted. The practical reach of the policy therefore depends on where an authorized link to it appears.

Supporting quotations

“Service” means any service or application offered by Roblox

It includes websites on the roblox.com domain, our Roblox mobile, virtual reality and consoles, the Roblox Player, the Roblox Studio

and our other websites, products, software, applications, content, data feeds and other services on which an authorized link to this Policy is posted

Qualifications & exceptions

• Covers other Roblox sites and products only where an authorized link to this Policy is posted.

Not stated here

• Which specific other sites or products carry an authorized link to this Policy is not listed in the source.

Legal Rights & Agreement Rules · Restriction or exception

Undefined capitalized terms come from the Roblox Dictionary, and the English version controls translations

Any capitalized term the policy does not define has the meaning set out in the Roblox Dictionary, which is a linked document. If there is a material or perceived conflict between the English version of the policy and translations, the English version controls.

Supporting quotations

Any other capitalized term that is not defined in this Policy is defined and has the meaning set out the Roblox Dictionary

In the event of a material or perceived conflict between the English version of this Policy and translations into other languages, the English version shall control.

Qualifications & exceptions

• The English version controls only where there is a material or perceived conflict with a translation.

Not stated here

• The Roblox Dictionary is linked but its text is not supplied here, so the card cannot say what any undefined term means.

Account & Service Control · User right or choice

Children under 13 have restricted access to certain features and are told to get a parent's permission

For users under 13 (defined as a "Child"), the policy says access to certain features is restricted to protect their Personal Information, and that Roblox is especially committed to protecting children's privacy. It tells children under 13 to get permission from a parent or guardian to use Roblox and says they should not use the Services without it. The text is an instruction to the child, not a described age or consent check.

Supporting quotations

If you’re under 13 years old, your access to certain features will be restricted in the interest of protecting your Personal Information.

If you’re under 13 years old, please get permission from your parent or guardian to use Roblox. You shouldn’t use our Services without their go-ahead.

“Children” or “Child” means any user under the age of 13

Qualifications & exceptions

• Applies to users under 13.
• "Certain features" are not listed in this passage.
• The policy tells the child to get permission; it does not describe how Roblox verifies this.

Not stated here

• Which features are restricted is not listed in this passage.
• Whether Roblox verifies parental permission is not stated in this passage.

Account & Service Control · User right or choice

Any user can limit who interacts with them or restrict their account; parents are only recommended to supervise

The policy says that, whatever your age, communication settings let you control who can interact with you, for example allowing only friends or no interactions at all. You can also restrict your account, which turns off chat and public commenting and limits the account to certain filtered experiences. For parents and guardians the policy only "recommend[s]" supervising children and points to a linked page about Roblox's safety features.

Supporting quotations

No matter how old you are, Roblox communication settings allow you to control who can interact with you, for example, by only allowing interactions with friends or not allowing any interactions at all.

You can also restrict your account, which turns off chat and public commenting and limits an account to certain filtered experiences on Roblox.

we recommend you supervise your child whenever they’re interacting on Roblox

Qualifications & exceptions

• The communication settings apply "no matter how old you are".
• Restricting an account turns off chat and public commenting and limits it to certain filtered experiences.
• Parent supervision is a recommendation.

Not stated here

• What the linked safety-features page says is not supplied here.

Use & Processing · Company commitment

Accounts under 13 start with stronger privacy settings, and ads are not personalized until the user is 18

For users under 13, Roblox says it will automatically set the account to stronger privacy settings. While in this privacy mode, features such as personalized advertising and alerts are disabled. At 13 the user can enable additional features appropriate for users 13 and up, but the policy says Roblox will not personalize ads until the user is 18.

Supporting quotations

If you’re under 13 years old, we’ll automatically set your account to have stronger privacy settings.

While in this privacy mode, some features like personalized advertising and alerts are disabled.

When you turn 13, you will be able to enable additional features that are more appropriate for users ages 13 and up (though we won’t personalize ads until you’re 18).

Qualifications & exceptions

• The stronger settings apply to users under 13 and are set automatically.
• From age 13 some features can be enabled; personalized ads stay off until 18.

Not stated here

• Which alerts and which additional features are meant is not listed in this passage.

Cross-references

• refers to (model-proposed): EEA/UK/Swiss list: under-13 accounts start with privacy-protective settings, without personalized ads and some alerts — The EEA/UK/Swiss list repeats the under-13 privacy-protective defaults described in the under-13 part.

Data Access & Collection · Company practice

An under-13 account needs a username, password and birth date; gender is optional

The policy says that when a user under 13 creates an account, Roblox asks for a username, password and date of birth (all required) and a gender (optional). The stated uses are: the username to create the account and run the Service, and not to identify the user outside Roblox; the password to log in; the date of birth to give the account default settings intended for the age; and gender to customize the experience. The policy calls this "non-personal information, as defined by COPPA", without explaining that term in this passage.

Supporting quotations

If you’re under 13 years old and create an account, we ask for some information (which is non-personal information, as defined by COPPA) to let you use Roblox.

We’ll collect:

your username (required). We need this to create your account and run the Roblox Service. We don’t use your username to identify you outside of Roblox

your password (required). We need this to log you in to your account and to run the Roblox Service

your date of birth (required). We’ll use this information to make sure your account has certain default settings intended for your age

your gender (optional). We will use this information to customize your experience

Qualifications & exceptions

• Applies when a user under 13 creates an account.
• Username, password and date of birth are required; gender is optional.
• The "non-personal information" label is Roblox's statement and is tied to COPPA.

Not stated here

• What COPPA's definition covers is not explained in this source.
• How this label fits with the policy's own definition of Personal Information is not explained.

Data Access & Collection · Company practice

A parent's email address is optional for a child account, but Roblox may use it to log in and to contact the parent

The policy says a child can provide a parent's or guardian's email address in account settings or at logout, for additional account security and parental controls. Children are encouraged, but not required, to provide it. Roblox says parent email addresses are collected for the security and integrity of the account and the platform, that it may use the address to log the child in, and that it may use it to communicate with the parent about the account, such as asking them to review it.

Supporting quotations

you have the option to provide a parent’s or guardian’s email address in account settings or during logout

Children are encouraged to provide a parent’s email address, but are not required to do so to create an account.

Parent email addresses are collected for the security and integrity of your account and the Roblox platform.

We may use your parent’s email address to log you in. We may also use your parent’s email address to communicate with them about your account, like asking them to review your account.

Qualifications & exceptions

• Providing a parent email is optional.
• Roblox says it "may" use the address for login and to communicate with the parent.

Not stated here

• How often Roblox contacts the parent is not stated.

Data Access & Collection · Company practice

Roblox collects persistent identifiers from children for six internal operations, including contextual ads

The policy says that when children sign up, Roblox also collects persistent identifiers such as IP address and unique device identifiers, which can recognize the child, the device or a household device. It says Roblox collects these and the information requested at sign-up for six internal operations: maintaining or analyzing how Roblox functions, network communications, authenticating users or personalizing content, serving contextual advertising including frequency capping, protecting security or integrity, and legal or regulatory compliance. Roblox says it implements technical, contractual and other measures so the identifiers are not used for other purposes.

Supporting quotations

When children sign up for Roblox, we also collect certain types of personal information called persistent identifiers for internal operations and to provide you and other users with Services.

Persistent identifiers are data like IP Address and unique device identifiers

Persistent identifiers can be used to recognize you, your device, or your household device.

Maintaining or analyzing the functioning of Roblox;

Performing network communications;

Authenticating users of, or personalizing the content on, Roblox;

Serving contextual advertising, including capping the frequency of ads;

Protecting the security or integrity of Roblox;

Ensuring legal or regulatory compliance.

Roblox implements technical, contractual, and other measures to ensure that persistent identifiers are not used for purposes other than those listed above.

Qualifications & exceptions

• Applies when children sign up for Roblox.
• Use is limited to the six listed internal operations.
• The policy lists "contextual advertising" among them, which is separate from the personalized advertising disabled for under-13s.

Not stated here

• The specific technical and contractual measures are not described.

Sharing & Disclosure · Company practice

Service providers may process children's persistent identifiers under contractual protections

Roblox says it relies on service providers to support the internal operations above, and that in some cases these providers may process persistent identifiers from users under 13. It says their processing is subject to contractual requirements and other measures to protect the security, confidentiality and integrity of the information.

Supporting quotations

Roblox relies on service providers to support the internal operations described above. In some cases, these entities may process persistent identifiers from users under the age of 13.

subject to contractual requirements and other measures to protect the security, confidentiality, and integrity of the information

Qualifications & exceptions

• Providers are used "to support the internal operations described above".
• Processing is "in some cases"; which cases is not stated.

Not stated here

• Which providers receive the data and which protections apply in each case are not listed.

Retention & Deletion · Company commitment

If a child gives more Personal Information than needed, Roblox deletes it, cancels the account or turns on protections

The policy says that a user under 13 will only be asked for the information needed to set up or protect the account. If the user gives more of their Personal Information, Roblox says it will do one of three things: delete any additional Personal Information it collected (unless the law requires it to keep it), cancel the account, or turn on age-appropriate protections on the account. The policy does not say what decides which of the three applies.

Supporting quotations

We don’t want more Personal Information

If you’re under 13 years old, we will only ask you to tell us the information we need to set up or protect your account. If you give us more of your Personal Information, we will:

delete any additional Personal Information we’ve collected from you (unless the law requires us to keep it),

cancel your account, or

turn on age-appropriate protections on your account

“Personal Information” means any information relating to a natural person who can be identified, directly or indirectly

Qualifications & exceptions

• Applies when a user under 13 gives more information than is needed to set up or protect the account.
• Deletion of the additional information is subject to a legal-retention exception.
• The three actions are listed as alternatives ("or").

Not stated here

• What decides which of the three actions is taken is not stated.

Use & Processing · Company practice

Roblox filters public chat and comment areas to remove personal details, phishing and offensive content, imperfectly

The policy says that when users publish anything in public and comment areas, such as chat, forums, group walls and personal posts, Roblox filters it and removes Personal Information like addresses, emails and phone numbers, phishing attempts, and offensive words or adult or suggestive content. It uses human and automated checking "to the best of our ability based on available technology" and says these systems are not 100% effective. The passage appears in the part of the policy addressed to users under 13, but its wording refers to "users" without an age limit.

Supporting quotations

When users publish anything in our public and comment areas (for example, chat, forums, group walls, personal posts), we filter it and remove:

Personal Information like addresses, emails, phone numbers

attempts at phishing (this is when someone tries to trick you into giving out Personal Information)

offensive words, adult or suggestive content

we use human and automated checking to the best of our ability based on available technology – but like all filtering technology, these systems aren’t 100% effective.

Qualifications & exceptions

• Applies to content published in public and comment areas.
• The passage sits in the under-13 part of the policy; its wording says "users" without an age limit.
• Roblox states the filtering is not 100% effective.

Not stated here

• Whether the same filtering is described for all ages is addressed in other sections, not in this passage.

Retention & Deletion · Company practice

Persistent identifiers are kept while you have an account, and up to two years after deletion for safety

Roblox says it maintains a retention policy designed to limit retention to what is reasonably necessary for the purposes it collected the information and to stop persistent identifiers being kept indefinitely, and that it uses access controls, purpose-based tagging, employee training and data segregation. It says it may retain persistent identifiers for different periods based on its business needs. To maintain an account (for example remembering its configuration and activity history) it stores persistent identifiers for as long as the account exists. When you delete your account Roblox initiates permanent deletion of data in its systems, but for safety and security (for example bot prevention) it may process persistent identifiers for up to two years after account deletion.

Supporting quotations

Roblox maintains a retention policy designed to limit data retention to what is reasonably necessary to fulfill the specific purposes for which we collected your information and to prevent persistent identifiers from being retained indefinitely.

Roblox may retain the persistent identifiers that we collect from you for different periods of time based on our specific business needs

Roblox stores persistent identifiers for the amount of time you have an account.

When you delete your account, Roblox initiates permanent deletion of data in our systems.

For safety and security purposes (e.g., bot prevention), Roblox may process persistent identifiers for up to two years after account deletion.

Qualifications & exceptions

• Retention periods vary by business need.
• Persistent identifiers are stored for as long as you have an account.
• Up to two years after account deletion for safety and security purposes; stated as "may".

Not stated here

• The retention periods for categories other than persistent identifiers are not given in this passage.
• What counts as a "business need" beyond the listed examples is not defined.

Cross-references

• refers to (model-proposed): Roblox keeps Personal Information as long as needed for its purposes, then de-identifies or deletes it — The data retention statement for persistent identifiers sits within the under-13 part, while the general retention passage in the looking-after-information part covers Personal Information more broadly; neither states fixed periods for all categories.

Data Access & Collection · Company practice

To assess age Roblox may collect images such as a selfie, deleted when the age check ends

The policy says Roblox may collect information about you, including images such as a selfie, to perform age assurance. It says information collected to assess ages, such as images taken for facial age estimation, is deleted once the age assurance process is complete. For more it points to the Roblox Facial Media Capture Policy, a linked document.

Supporting quotations

Age Assurance

To assess user ages, Roblox may collect information about you, including images such as a selfie, to perform age assurance.

Information collected to assess user ages, such as images taken to perform facial age estimation, is deleted once the age assurance process is complete.

Qualifications & exceptions

• Roblox "may" collect the information; it does not say when age assurance is required.
• Deletion is stated to happen once the age assurance process is complete.

Not stated here

• The Facial Media Capture Policy is linked but its text is not supplied here, so the card cannot say what it provides.
• The source does not say when the process is complete or what results of the check Roblox keeps.

Retention & Deletion · Company commitment

A parent email given to set up a parent account is deleted within 24 hours if the parent does not finish linking

The policy says that if you give Roblox your parent's email in order to establish a parental account, Roblox deletes that email within 24 hours if your parent does not complete the linking process.

Supporting quotations

Linking to Parent Accounts

If you provide Roblox with your parent’s email for the purposes of establishing a parental account, Roblox deletes your parent’s email within 24 hours if your parent does not complete the linking process.

Qualifications & exceptions

• Applies when the parent email is provided to establish a parental account and the parent does not complete linking.

Not stated here

• What happens to the email if the parent does complete linking is not stated in this passage.

Retention & Deletion · Restriction or exception

Roblox may keep information longer when law or regulation requires it

The policy says Roblox may also retain information for longer periods if it is required to do so for legal or regulatory compliance. This applies on top of the retention periods described above.

Supporting quotations

Meeting Legal Obligations

Roblox may also retain information for longer periods if we are required to do so for legal or regulatory compliance.

Qualifications & exceptions

• Applies where retention is required for legal or regulatory compliance.

Not stated here

• Which laws or the length of such retention are not specified.

Account & Service Control · User right or choice

You can ask Roblox to change a child's account or to review, delete or stop collection of Personal Information

The policy says you can ask Roblox to make changes to your child's account or to let you review, delete, or prevent further collection or use of Personal Information from you or your child. The way to make a request is to fill out the Customer Support Form.

Supporting quotations

Please ask us if you want to make privacy-related changes

You can request that Roblox make changes to your child’s account or allow you to review, delete, or prevent the further collection or use of Personal Information from you or your child. To make a request, please fill out our Customer Support Form

Qualifications & exceptions

• Requests are made through the Customer Support Form.
• The passage is addressed to a parent or a user about "you or your child".

Not stated here

• Response timing and any limits on these requests are not stated in this passage.
• The Customer Support Form is linked but its text is not supplied here.

Legal Rights & Agreement Rules · Company commitment

Roblox says it complies with COPPA in the US and links to outside guides

For the US, Roblox says it complies with the Children's Online Privacy Protection Act ("COPPA") and points to the US Federal Trade Commission's COPPA website and to a guide from the kidSAFE Seal Program. The policy does not describe in this passage what compliance consists of; the linked pages are not part of the supplied source.

Supporting quotations

In the US and want to know more? We comply with the Children’s Online Privacy Protection Act (“COPPA”).

You can also learn more about COPPA by looking at this simple guide from the kidSAFE Seal Program

Qualifications & exceptions

• The statement is made for the United States.

Not stated here

• What COPPA requires and the content of the FTC and kidSAFE pages are not supplied in this source.
• The kidSAFE link as written in the source appears to be a malformed address; where it leads is not established.

Data Access & Collection · Company practice

Sign-up asks for username, password, birthday, optional gender; eligible users may put certain data in display names

The policy says that to join, a user sets up an account with a unique username and password, and is also asked for a birthday and gender (gender is optional) so Roblox can customize the experience. It adds that eligible users may set their account's display name to contain certain Personal Information. It says Roblox does not use the username to identify the user outside their activity on Roblox. It gives three signing-up rules: do not use your own name or other Personal Information in your username, do not pick an easy-to-guess password, and you may share your password with a parent or guardian but not with others.

Supporting quotations

Setting up a Roblox account

We’ll ask you to create a unique username and password so you can log into your account and access features on Roblox. We also ask you for your birthday and gender (gender is optional) so we can customize your experience on Roblox.

Eligible users may set their account's display name to contain certain Personal Information.

Three key rules for signing up:

Do not use your own name or other Personal Information in your username.

Do not pick a password that’s easy to guess.

You may share your password with your parent or guardian, but do not share it with others.

We don’t use your username to identify you outside of your activity on Roblox.

Qualifications & exceptions

• "Eligible users" may put certain Personal Information in the display name; who is eligible and what is permitted is not stated here.
• Gender is optional.
• The three rules are directions to the user.

Not stated here

• Which users are "eligible" and which Personal Information a display name may contain are not stated.

Data Access & Collection · Company practice

Roblox asks for an email address mainly for security; a hash is saved if a 13+ account changes its birthday to under 13

The policy says that once you have an account you can add an email address (a parent's or guardian's if you are under 13) in case you need to reset your password. Roblox may ask for your email to verify your identity or enable additional features, and says its main reason is security, to check that accounts are authentic. You can change the email address at any time, and if it is changed Roblox sends a notification email to the previous address. If a 13+ account changes its birthday to indicate an age under 13, Roblox saves a hash of that email address and any email addresses previously collected from the user; it says the hash cannot be reconstructed into the address or used to contact the user and will only be used to authenticate the user in the future.

Supporting quotations

Why we ask you for an email address:

Once you have an account, you can add your email address (or your parents’ or guardians’ email address if you are under 13) in case you need to reset your password.

We might ask for your email to verify your identity or enable additional features. The main reason we need an email address is for security because it is how we check to make sure accounts are authentic.

You can change your email address anytime you want – if an email address is changed, we’ll send a notification email to the address that you used before.

If you have a 13+ account and change your birthday to indicate you are under age 13, Roblox will save a hash of your email address and any email addresses previously collected from you. This hash cannot be reconstructed back into your email address or used to contact you, and will only be used to authenticate you in the future.

Qualifications & exceptions

• For users under 13 the address is a parent's or guardian's.
• The hash rule applies where a 13+ account changes its birthday to indicate under 13.
• Roblox says it "might" ask for email to verify identity or enable additional features.

Not stated here

• Which additional features may require an email address are not listed.

Data Access & Collection · Company practice

A phone number you give is texted to confirm, used for security and access; you authorize your carrier to share data

The policy says that if you choose to give a phone number, Roblox sends a text message asking you to confirm it before you can log in, and uses the number for security and account access, including to recover a lost or forgotten password, access a feature, or log in via mobile. It also says you authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Roblox or its service provider for the duration of your business relationship, solely to help them identify you or your device and to prevent fraud.

Supporting quotations

Sharing your phone number

If you choose to give a phone number, we’ll send you a text message asking you to confirm your number before you can log in.

We will use your phone number for security and account access, including to recover a lost or forgotten password, access a feature, or log in via mobile.

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Roblox or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.

Qualifications & exceptions

• Providing a phone number is a choice.
• The carrier authorization is limited to identifying you or your device and preventing fraud, for the duration of your business relationship.

Not stated here

• What information a carrier holds and may disclose is not described in this passage.

Linking & Identification · User right or choice

With your consent, Roblox may use your phone number to recommend you as a friend, possibly showing your real name

The policy says that, with explicit and informed consent, Roblox may use your phone number to recommend you as a friend to others on Roblox. You are recommended with your contact name as stored on your friends' devices, which may also include your real name. If you do not want your phone number used so friends can find you, the policy says not to activate the feature or to deactivate it at any time. It adds that the Discoverability feature may not be available in certain locations.

Supporting quotations

with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Roblox

You will be recommended with your contact name as stored on your friends’ devices, which may also include your real name.

please do not activate this feature or deactivate it at any time

the Discoverability feature may not be available in certain locations

Qualifications & exceptions

• Requires explicit and informed consent.
• You can deactivate the feature at any time.
• The Discoverability feature may not be available in certain locations.

Not stated here

• Which locations lack the feature is not stated in this passage.

Charges & Financial Obligations · Company practice

Buying Robux or subscriptions requires billing information, from a parent if you are under 13

The policy says you can buy Robux or premium subscriptions and choose how to pay from the available methods. When you pay, you (or a parent or guardian if you are under 13) will have to give billing information including Personal Information such as the name of the person responsible for the purchase, their billing address and contact details like email or phone number, and credit card or other payment information.

Supporting quotations

You can buy Robux or premium subscriptions and choose how to pay from our available payment methods.

When you pay, you (or your parent or guardian if you’re under 13) will have to give billing information, including Personal Information such as:

Name of the person responsible for buying Robux

Their billing address and contact details, like email or phone number

credit card or other payment information

Qualifications & exceptions

• For users under 13, the parent or guardian gives the billing information.
• The list is introduced by "such as", so it is not stated to be complete.

Not stated here

• Whether other billing details can be required is not stated.

Sharing & Disclosure · Company practice

Payment processors run transactions under their own policies; Roblox says it lacks full saved billing details

The policy says payment processors (for example PayPal) manage transactions and those are subject to the processors' own terms and privacy policies, which explain what Personal Information they keep and use. As an example, processors might keep your billing information, transaction details and purchase history to sort out billing problems. Roblox receives certain information about purchases to fulfill its legal obligations and support the integrity of the platform, and may also collect your billing address for payment and integrity purposes. If you choose to save billing information with a processor, Roblox says it does not store or have access to your full saved billing information. If you buy Robux for another Roblox user, Roblox collects contact information such as email or phone number in order to communicate with you about the transaction.

Supporting quotations

Our payment processors (for example, PayPal) manage the transactions, which are subject to their terms and conditions and privacy policies.

Roblox receives certain information about purchases in order to fulfill our legal obligations and support the integrity of our platform. Roblox may also collect your billing address for payment and integrity purposes.

You can choose to save your billing information with one of our payment processors to make future purchases easier, in that case, Roblox does not store or have access to your full saved billing information.

If you purchase Robux on behalf of another Roblox user, we collect contact information, such as email or phone number, in order to communicate with you about the transaction.

Qualifications & exceptions

• Processors' own policies govern what they keep.
• The statement about not storing full billing information applies to information saved with a processor.
• Roblox collects contact information when you buy Robux on behalf of another user.

Not stated here

• The processors' policies are not supplied, so what they keep is not established here.
• What "certain information about purchases" Roblox receives is not listed.

Use & Processing · Company practice

Content you post may be captured or shared by others, and Roblox monitors it and may change or remove it

The policy says you can post comments, messages or other content through chats, forums, group walls, personal posts or other features, and that users 13 or older can also use audio features. It says content you post, including chat or audio, may be captured or shared by other users. Roblox says it monitors what you say and write to check it meets its Community Standards and complies with its Terms of Use, and that if the content does not meet its standards, for example if Roblox believes it is inappropriate, includes Personal Information or is not suitable for users, it has the right to change or remove it.

Supporting quotations

Posting content

You can post comments, messages, or other content on Roblox through chats, forums, group walls, personal posts, or other features. Users who are age 13 or older can also use audio features on Roblox.

Content you post, including your chat or audio, may be captured or shared by other users.

We monitor what you say and write to check that it meets our Community Standards and complies with our Terms of Use.

we have the right to change or remove it

Qualifications & exceptions

• Audio features are available to users 13 or older.
• Roblox's right to change or remove applies where it believes content does not meet its standards.

Not stated here

• The Community Standards and Terms of Use are not supplied in this source.

Use & Processing · Permission or license

Where the law allows, Roblox may use posted content to train and improve its filters and for a better experience

The policy says that, where the law allows, Roblox may use the content you and other users have posted for training or to help improve the way it filters content on the platform. It says the aim is to increase safety and that it may also use this data to help provide a better experience on Roblox and to respond to requests about your account from you or your parent or legal guardian.

Supporting quotations

Where the law allows us to, we may use the content you and other users have posted for training or to help us to improve the way we filter content on our platform.

Our aim is to increase safety on our platform. We also may use this data to help us provide a better experience on Roblox and to respond to requests about your account from you or your parent or legal guardian.

Qualifications & exceptions

• Training use applies "where the law allows us to".
• Stated purposes are filtering improvement, safety, a better experience and responding to account requests.

Not stated here

• Which laws limit this use is not stated in this passage.
• Whether "training" covers only content filters is not stated; the passage mentions filter improvement as the example.

Data Access & Collection · Company practice

Contacting support collects your email (a parent's if under 13) and username; records are kept for a limited time

The policy says that when you contact customer support, report a problem, ask for technical support or ask questions or give comments, Roblox collects your email address (or a parent's or guardian's if you are under 13), your username and any other details you give. It uses this to answer questions and give the support asked for; for users under 13 it communicates with the parent or guardian when sending responses. It retains records of technical support questions for a limited time for internal use only, such as answering additional questions about your account.

Supporting quotations

We collect your email address (or your parents’ or guardians’ email address if you are under 13), username, and any other details you give when you:

contact customer support

report a problem

ask for technical support

ask us questions or give us comments

We use this information to answer your questions and to give you the support or help you ask for. For users under 13, we communicate with your parent or guardian when sending our responses.

We retain records of technical support questions for a limited time for internal use only, such as to answer additional questions about your account.

Qualifications & exceptions

• For users under 13, responses go to the parent or guardian.
• Records are retained for a "limited time" and used internally only.

Not stated here

• The length of the limited retention time is not stated.

Use & Processing · Company practice

Roblox may use your email and verified date of birth to provide access to certain features

The policy says Roblox may use Personal Information when you use certain Roblox features, and that to provide access to certain features it may use your email address and other information you provide, such as your verified date of birth. The passage does not name which features.

Supporting quotations

Using Roblox features

We may use Personal Information when you use certain Roblox features. To provide access to certain features, we may use your email address and other information you provide to us, such as your verified date of birth.

Qualifications & exceptions

• Applies to "certain" features, which are not named.

Not stated here

• Which features this covers is not stated in this passage.

Linking & Identification · User right or choice

Users 13 and older can add social media links; Roblox may see information about those accounts

For users 13 and older, the policy says you can add links to your other social profiles on your Roblox account and share them with other users, and that you control who can see them. It says that when you use these features Roblox may be able to see information about your social media accounts. A separate sentence says that if you use your Roblox ID to sign in to a non-Roblox website or service and later delete your Roblox account, you may lose access to that website or service. That sentence follows the social-links list without its own heading, so the source does not state whether it is limited to this feature.

Supporting quotations

Social Media Links (users 13 and older)

You can add links to your other social profiles on your Roblox account. This allows you to share these links with other users. You control who can see the Social Media links associated with your account.

When you use these features:

we may be able to see information about your social media accounts.

If you use your Roblox ID to sign in to a non-Roblox website or service, and later delete your Roblox account, you may lose access to that website or service.

Qualifications & exceptions

• Applies to users 13 and older.
• You control who can see the links.
• Roblox "may be able to see" information about social accounts; which information is not stated.

Not stated here

• Which information about social accounts Roblox can see is not stated.
• Whether the sign-in sentence belongs only to the social-links feature is not stated.

Cross-references

• qualifies (model-proposed): EEA/UK/Swiss list: Roblox may access linked social account information; deleting Roblox may cut off third-party sign-ins — The general passage leaves unclear whether the sign-in sentence belongs to the social links feature; the EEA/UK/Swiss list puts the same sentence in the social media links item.

Use & Processing · Company practice

Voice and audio you use is monitored, collected, used and stored for voice chat, safety, training and screen recordings

For users 13 and older, the policy says that if you use Roblox's audio features, Roblox will monitor, collect, use and store audio captured through your device for four purposes: to enable voice chat; to make voice-related services safer, including to detect and combat abuse and other harmful activity; in accordance with applicable law, to inform training and product improvement; and in connection with screen recordings that Creators and Users produce through the Services.

Supporting quotations

Audio features (users 13 and older)

If you use Roblox’s audio features, we will monitor, collect, use, and store audio captured through your device:

to enable voice chat,

to make our voice-related services safer, including to detect and combat abuse and other harmful activity on our Services,

in accordance with applicable law, to inform training and product improvement, and

in connection with screen recordings that Creators and Users produce through the Services.

Qualifications & exceptions

• Applies to users 13 and older who use audio features.
• Training and product improvement use is "in accordance with applicable law".
• Screen recording use is in connection with recordings Creators and Users produce.

Not stated here

• How long audio is stored is not stated in this passage.
• What applicable law limits training use is not stated.

Cross-references

• contrast (model-proposed): EEA/UK/Swiss list: no training on EEA private server voice chat; other voice training only with consent — The general audio passage says audio may be used, in accordance with applicable law, to inform training and product improvement. The EEA/UK/Swiss list says Roblox will not train on private server voice chat recordings of EEA users and uses voice recordings for training only with consent. The cards report both without deciding how they combine; Section 7 prevails on conflict for the locations it covers.
• contrast (model-proposed): Brazil list: no training on private server voice chat of Brazil users; other voice training only with consent — The Brazil list makes a similar commitment not to train on private server voice chat recordings of Brazil users, with training from voice recordings using consent, whereas the general audio passage lists training and product improvement in accordance with applicable law.

Legal Rights & Agreement Rules · Context

Information about laws that apply in your region is in Section 7

The policy says that for more information about laws that apply in your region, you should visit Section 7 of the policy. Section 7 is also the part that prevails over Sections 1-5 where they conflict.

Supporting quotations

For more information about laws that apply in your region, please visit Section 7 of this policy.

Qualifications & exceptions

• Pointer only; the regional detail is in Section 7.

Not stated here

• What Section 7 provides for any given region is shown by the cards for that section, not by this pointer.

Data Access & Collection · User right or choice

Users 13 and older who agree may have their geolocation collected and tracked, using a device or browser identifier

For location-based Services, available to users 13 or older, the policy says that if you agree Roblox may collect and track geolocation information so it can offer Services that depend on knowing where you are. It says this is done using an identifier on your device or browser so Roblox can recognize you each time you return. To stop location collection you can update your device settings, stop using the Service, or uninstall the mobile apps.

Supporting quotations

Location-based Services (users 13 and older)

You can choose to use location-based Services if you’re 13 or older. If you agree, we may collect and track geolocation information so that we can offer Services that depend on us knowing where you are.

We collect this information by using an identifier on your device or browser so that we can recognize you each time you return.

To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.

Qualifications & exceptions

• Applies to users 13 and older.
• Collection depends on your agreement.
• The ways to stop collection are device settings, stopping use of the Service, or uninstalling the apps.

Not stated here

• Which Services depend on location is not listed in this passage.

Data Access & Collection · Company commitment

On a VR platform Roblox collects your physical movement information and says it does not store it

The policy says that if you join its experiences on a VR platform, Roblox collects your physical movement information so it can use it in the experience. It says the information is only used to provide the experience and that Roblox does not store it.

Supporting quotations

Joining on a VR platform

If you join our experiences on a VR platform, we collect your physical movement information so that we can use it in the experience. This information is only used to provide the experience.We do not store this information.

Qualifications & exceptions

• Applies when you join experiences on a VR platform.
• Use is stated to be only to provide the experience; no storage.

Not stated here

• Whether the VR platform provider keeps this information is not addressed.

Data Access & Collection · Company practice

Camera features and uploads (13+) are collected, processed and stored, including for safety checks

For users 13 and older, the policy says that if you use features that require your camera or let you upload content containing your Personal Information, including photos, Roblox will collect, process and store that content to accomplish the purpose of the feature, including processing the content for safety purposes. It says video used to generate animation key frames is processed on your device and is not shared with Roblox or any third parties. It refers to a Roblox Facial Animation Privacy Notice and a Roblox Facial Media Capture Privacy Notice for more, including ID Verification.

Supporting quotations

Camera-enabled features and uploads (users 13 and older)

we will collect, process, and store that content to accomplish the purpose of the feature, including processing the content for safety purposes

Video used to generate animation key frames is processed on your device and is not shared with Roblox or any third parties.

For information about how Roblox uses ID Verification, please refer to the Roblox Facial Media Capture Privacy Notice

Qualifications & exceptions

• Applies to users 13 and older.
• Storage is to accomplish the purpose of the feature, including safety processing.
• Animation key-frame video is processed on the device and not shared with Roblox or third parties.

Not stated here

• The two linked privacy notices are not supplied here, so the card cannot say what they provide, including for ID Verification.
• How long the content is stored is not stated in this passage.

Data Access & Collection · Company practice

If you opt in to Contact Importer, Roblox collects your contacts' names and phone numbers and keeps only matches

For users 13 and older, the policy says that if you opt in to the Contact Importer feature you share the first and last names and phone numbers of the contacts in your mobile phone address book with Roblox, to help connect with friends. If you use it, Roblox automatically accesses and collects address book information from time to time to sync contacts. It says such information is only retained in case of matches with existing Roblox users, and that the feature is only available to users 13 or older and may not be available in certain locations.

Supporting quotations

Contact Importer (users 13 and older)

If you opt-in to the Contact Importer feature, you will share the first and last names and phone numbers of your contacts in your address book on your mobile phone with Roblox.

we will automatically access and collect information in your address book from time to time in order to sync your contacts. Such information will only be retained in case of matches with existing Roblox users.

Our Contact Importer feature is only available if you are 13 or older and may not be available in certain locations.

Qualifications & exceptions

• Opt-in.
• Applies to users 13 and older and may not be available in certain locations.
• Address book information is retained only where it matches existing Roblox users.

Not stated here

• What happens to non-matching information beyond "not retained" is not described; the passage says collection recurs "from time to time".
• Which locations lack the feature is not stated.

Sharing & Disclosure · Company practice

Joining a Creator Event shares your username, email and user ID with the hosting company

For users 13 and older, the policy says that if you join a virtual event hosted by a Creator, data such as your username, email and Roblox user ID may be shared with the company that hosts the events, to allow you to log in to the experience. It says your activity during a Creator Event is subject to the third-party platform's privacy policy as well as the Roblox Community Standards, and that Creator events are only available to users 13 or older.

Supporting quotations

Creator Events (users 13 and older)

If you join a virtual event hosted by a Creator, data such as your username, email, and Roblox user ID may be shared with the company that hosts the events. This is done to allow you to log in to the experience.

Your activity during a Creator Event is subject to the third party platform’s privacy policy as well as the Roblox Community Standards. Creator events are only available if you are 13 or older.

Qualifications & exceptions

• Applies to users 13 and older.
• The data listed is introduced by "such as".
• The third-party platform's privacy policy governs your activity during the event.

Not stated here

• The third-party platform's privacy policy is not supplied, so what that platform does with the data is not established.

Use & Processing · Company practice

Roblox collects information about how you interact with the Services and links it to your account

The policy says that to improve your experience and support safety, Roblox collects information about how you interact with the Services and connects it with your account. Examples it gives: information from your game state to detect Terms violations and improve that detection; information about your behavior when you interact with your device for security and safety; information about the games you play to give similar recommendations; and information from your device through cookies, which it refers to the "Cookies and Similar Technologies" section.

Supporting quotations

Interacting with our experiences

we collect information about how you interact with the Services and we connect this information with your account. For example, we may:

collect information from your game state to detect violations of our Terms and to improve our ability to detect such violations.

collect information about your behavior when you interact with your device for security and safety purposes

collect information about the games you are playing to give you similar recommendations

collect information from your device through cookies - see “Cookies and Similar Technologies”.

Qualifications & exceptions

• The list is introduced by "for example", so it is not stated to be complete.
• Information is connected with your account.

Not stated here

• What "behavior when you interact with your device" covers is not defined in this passage.

Cross-references

• contrast (model-proposed): EEA/UK/Swiss list: interaction data, game state and recommendations rest on contract and legitimate interest — The general interaction passage names the games you are playing as a recommendation input; the EEA/UK/Swiss list (and Brazil list) names search history. The cards report both without deciding whether they describe the same data.
• contrast (model-proposed): Brazil list: interaction data, game state, search history and UGC details are collected and linked to your account — The Brazil list names search history for recommendations where the general passage names the games you are playing.

Sharing & Disclosure · Company practice

Your username and transaction details may be shared with the creator or later owner of UGC you acquire

The policy lists, among the examples of what Roblox may do, sharing information like your username and transaction details with the UGC creator or subsequent owners if you acquire a limited item, purchase, share, trade or otherwise engage in a transaction involving UGC.

Supporting quotations

share information like your username and transaction details to the UGC creator or subsequent owners, if you acquire a limited item if you purchase, share, trade, or otherwise engage in a transaction involving UGC,

Qualifications & exceptions

• Applies when you acquire a limited item or engage in a transaction involving UGC.
• Recipients are the UGC creator or subsequent owners.

Not stated here

• What "transaction details" include is not defined in this passage.

Data Access & Collection · Company commitment

For other features for users 13 and older, Roblox says it will set out what is collected when it collects it

The policy says that when you subscribe to other features or activities available to users 13 or older, Roblox will set out what information is collected and how it intends to use it at the time the information is collected. The policy itself does not list those features.

Supporting quotations

Subscribing to other features (users 13 and older)

we’ll set out what information is collected and how we intend to use it when the information is collected

Qualifications & exceptions

• Applies to features or activities available to users 13 or older.
• The details are given when the information is collected, not in this policy.

Not stated here

• Which features this covers and what they collect are not stated in this policy.

Sharing & Disclosure · Company practice

Competitions and promotions may require contact details; gift card providers may receive them; winners may be published

The policy says that taking part in competitions or promotions such as contests, sweepstakes, giveaways or prize draws may require contact information such as name, email or phone number to be eligible for discounts or prizes. If you receive a gift card from a third-party provider, certain contact information may be shared with the provider and used in accordance with this Policy and the terms on the provider's website. In some places the law requires Roblox to publicly share information about winners.

Supporting quotations

Competitions, promotions and research

Taking part in competitions or promotions

those activities may require contact information such as your name, email, or phone number, to be eligible for discounts or prizes

If you receive a gift card provided by a third party provider, certain contact information may be shared with the provider and used in accordance with this Policy and the terms listed on the provider’s website.

In some places in the world, the law requires us to publicly share information about the winners.

Qualifications & exceptions

• Applies when you take part in competitions or promotions.
• Sharing with a gift card provider applies where you receive a gift card from a third-party provider.
• Public sharing of winner information applies in some places where the law requires it.

Not stated here

• The third-party provider's terms are not supplied here.
• Which places require public sharing of winners, and what is shared, are not stated.

Data Access & Collection · Company practice

Research or surveys you join may collect your interests, habits and lifestyle information

The policy says that if you choose to participate in research or surveys, these may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences, and may ask for Personal Information.

Supporting quotations

Taking part in research

If you choose to participate in research or surveys, these surveys may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for Personal Information.

Qualifications & exceptions

• Participation is your choice.
• The examples of information are not stated to be complete.

Not stated here

• Who runs the surveys and how the answers are used are not stated in this passage.

Use & Processing · Company practice

Roblox uses collected information to decide which ads to show, and may work with partners to show ads

The policy says Roblox processes your Personal Information to display ads on Roblox and specifically uses information it collects to decide which ads to show you. It says Roblox also may work with partners to directly show you ads on Roblox.

Supporting quotations

Advertising

We process your Personal Information to display ads on Roblox. Specifically, we use information we collect to decide which ads to show you on Roblox.

Roblox also may work with partners to directly show you ads on Roblox.

Qualifications & exceptions

• Applies to ads displayed on Roblox.

Not stated here

• Which partners are involved and what information they receive is not stated in this passage.

Use & Processing · User right or choice

Under-18s see only nonpersonalized ads; users 18 and over see personalized ads, with consent where required

The policy says users under 18 will see only nonpersonalized ads. Users 18 and older will see personalized ads on Roblox, with consent where required, and users 18 or older can control whether they see personalized ads through their Roblox settings.

Supporting quotations

Users under 18 years old will see only nonpersonalized ads. Users 18 years old and older will see personalized ads on Roblox (with consent, where required).

If you are 18 or older, you can control whether you see personalized ads through your Roblox settings

Qualifications & exceptions

• The ad personalization rule depends on age: under 18 versus 18 and older.
• Consent is required where required by law; which places that is, is not stated.
• The personalized-ads control is available to users 18 or older.

Not stated here

• In which places consent is required is not stated in this passage.

Cross-references

• qualifies (model-proposed): EEA/UK/Swiss list: personalized ads rest on consent and are not shown to under-18s; other ads on legitimate interest — The general rule that users 18 and older see personalized ads with consent where required is given a consent basis in the EEA/UK/Swiss list, and both say users under 18 see no personalized ads.

Charges & Financial Obligations · Company practice

Publishing ads on Roblox means giving name, contact, financial and tax information for an ad account

The policy says that if you choose to publish ads on Roblox, Roblox collects additional information from you such as your name, email, address, financial information, and business and/or tax information. It states the purposes: to provide an ad account, onboard you to the ad program, send invoices or payment information, and comply with applicable laws, including tax laws.

Supporting quotations

If you choose to publish ads on Roblox, we collect additional information from you such as your name, email, address, financial information, business and/or tax information.

The purpose of collecting this information is to provide you with an ad account, onboard you to the relevant ad program, send you invoices or information related to payment, and comply with applicable laws, including tax laws.

Qualifications & exceptions

• Applies if you choose to publish ads on Roblox.
• The information listed is introduced by "such as".

Not stated here

• Whether other information may also be collected is not stated.

Charges & Financial Obligations · Company practice

Developer Exchange requires a tax form, may require a photo ID via a third-party vendor, and is for users 13+

The policy says that to take part in the Roblox Developer Exchange Program you must give Roblox an IRS W-9 form (US taxpayers) or W-8 form (non-US taxpayers). Roblox may also ask you to verify your identity by providing a government-issued photo ID through a third-party vendor. It says this feature is only available to users 13 or over, and refers to the Developer Exchange Terms of Use, a linked document.

Supporting quotations

If you’re a developer or creator

To take part in the Roblox Developer Exchange Program, you must give us an IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers).

We may also ask you to verify your identity by providing a government-issued photo ID through a third-party vendor.

This feature is only available to users who are 13 or over.

Qualifications & exceptions

• Applies to developers and creators taking part in the Developer Exchange Program.
• The tax form is required; the photo ID verification is something Roblox "may" ask for.
• Only available to users 13 or over.

Not stated here

• The Developer Exchange Terms of Use are linked but their text is not supplied here.
• The third-party vendor is not named in this passage.

Use & Processing · Company practice

Roblox also uses Personal Information to manage accounts, communicate, improve the Service, research and give support

The policy says Roblox also uses Personal Information for these general purposes, as permitted by law, in addition to the purposes listed above: to let you manage your account or update settings, to communicate with you about the Services, to operate, maintain, personalize and improve the Service, to research relevant technologies, and to provide technical support or customer service.

Supporting quotations

We also use Personal Information for these general purposes, as permitted by law, in addition to the purposes listed above:

To let you manage your account and our services

To allow you to manage your Roblox account or update your settings

To communicate with you about our Services

To make things better for you

To operate, maintain, personalize, and improve our Service

To research relevant technologies

To provide technical support or customer service

Qualifications & exceptions

• Stated to be "as permitted by law" and "in addition to" the purposes listed earlier.

Not stated here

• What "research relevant technologies" involves is not described.

Security & Safeguards · Company practice

Roblox also uses Personal Information for security, fraud prevention, access decisions, auditing and legal compliance

Under the same general purposes "as permitted by law", Roblox lists: detecting security issues and protecting against malicious, deceptive or illegal activity, and prosecuting anyone responsible; finding and fixing errors or bugs; giving you access to features or limiting your access to Roblox as appropriate; protecting its or its users' integrity, safety or security; auditing interactions and transactions and carrying out other compliance tasks; and complying with the law and its own Terms of Use or any other restrictions it has put on your use of the Service.

Supporting quotations

To protect you by keeping our platform safe and secure

To detect security issues, protect against malicious, deceptive or illegal activity, and prosecute anyone responsible for that activity

To find and fix errors or bugs

To give you access to features or limit your access to Roblox, as appropriate

To protect our or our users’ integrity, safety or security

To comply with the law and our policies

To audit interactions and transactions, and carry out any other compliance tasks

To comply with the law and our own Terms of Use, or any other restrictions we’ve put on your use of the Service

Qualifications & exceptions

• Stated to be "as permitted by law" and in addition to the purposes listed earlier.
• Roblox decides on access "as appropriate".

Not stated here

• The criteria for limiting access to Roblox are not stated in this passage.

Account & Service Control · User right or choice

You do not have to provide Personal Information, but withholding it may limit services and features

The policy says you are under no obligation to provide Personal Information to Roblox when requested. It adds that if you choose to withhold requested information, Roblox may not be able to provide you with certain services and features.

Supporting quotations

You are under no obligation to provide Personal Information to Roblox when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features.

Qualifications & exceptions

• Withholding may mean certain services and features are unavailable.

Not stated here

• Which services or features depend on which information is not stated here.

Data Access & Collection · Context

The policy explains cookies, pixel tags, session and persistent cookies, and first- and third-party cookies

Roblox says it uses cookies and other standard internet technologies, like most websites, to make its services better. It explains a cookie as a text file put on your computer or device when you visit a website that lets the site remember what you do and your settings, such as login information, language and font size. Session cookies are deleted when you close the browser; persistent cookies stay on the device for a defined period. A cookie set by the owner of the web server you visit is a first-party cookie, and one set by owners of other domains is a third-party cookie. A pixel tag or web beacon is a piece of code that tells its owner what you do on a web page, such as which pages you visited or which ads you clicked.

Supporting quotations

Cookies and similar technologies

Like most websites, we use cookies and other standard internet technologies to help us make our services better.

A cookie is a text file that’s put on your computer or device when you visit a website. It lets the website remember what you do and any settings you choose

Session cookies are deleted each time you close the browser

Persistent cookies stay on the device for a defined period of time.

A cookie set by the owner of the web server you are visiting is called a first-party cookie and cookies set by owners of other domains are called third-party cookies.

A pixel tag or web beacon is a piece of code that tells its owner what you do on a web page. Pixel tags provide information like which web pages you visited or which ads you clicked on.

Qualifications & exceptions

• Descriptive explanation of the technologies, not a statement of which are used.

Not stated here

• The "defined period" for persistent cookies is not given in this passage.

Use & Processing · Company practice

Roblox and third parties may use cookies to recognize you and customize your experience, only for purposes in the policy

The policy says Roblox uses technology like cookies to recognize you and customize your experience, and that Roblox and any third parties might use these technologies whenever you visit its sites or use its Services. It also says Roblox uses cookies or similar technologies only for the purposes given in the privacy policy.

Supporting quotations

How we use cookies

We use technology like cookies to recognize you and customize your experience. We and any third-parties might use these technologies whenever you visit our sites or use our Services.

We use cookies or similar technologies only for the purposes given in this privacy policy.

Qualifications & exceptions

• The statement that use is limited to the policy's purposes is made for Roblox ("we").
• Third parties "might" use the technologies; their purposes are not stated.

Not stated here

• Which third parties may use these technologies, and for what, is not stated in this passage.

Data Access & Collection · Company practice

Roblox collects device and software information, including IP address and device identifiers

The policy says Roblox collects information about the devices and software you use, for example the type of browser or device, the website or source that referred you, your IP address, device ID or other identifier that identifies your computer or mobile device (it says this cookie is not deleted when you close your browser), and the operating system of your computer or device.

Supporting quotations

We collect information about the devices and software you use, for example:

the type of browser or device

the website or source that linked or referred you to our services

your IP address, device ID or other identifier that identifies your computer or mobile device – this cookie is not deleted when you close your browser

the operating system of your computer or device

Qualifications & exceptions

• The list is introduced by "for example", so it is not stated to be complete.
• The IP address and identifier cookie is stated not to be deleted when you close the browser.

Not stated here

• How long the identifier cookie lasts is not stated.

Data Access & Collection · Company practice

These technologies let Roblox remember settings, measure use, spot fraud and collect demographic information

The policy says these technologies allow Roblox to: record and keep your preferences, account settings and certain login information (for convenience and security); collect information about how you use the Services, such as how or where you downloaded the app; collect information on how software is used on your mobile device; collect information about what features you use and how well its services work; identify suspicious activities so it can try to protect users from payment fraud and other inappropriate activities; collect demographic information (the policy gives age and location as examples); and perform similar functions.

Supporting quotations

These technologies allow us to:

record and keep your preferences, account settings, and certain login information (for your convenience, e.g. to prevent you from needing to choose settings every time you visit, and security)

collect information about how you use the Services, for example, how you downloaded our app or where you downloaded it from

collect information on how software is used on your mobile device

collect information about what features you use and how well our services work

identify any suspicious activities so we can try to protect users from payment fraud and other inappropriate activities

collect demographic information (eg, age, location, etc)

perform similar functions.

Qualifications & exceptions

• The list ends with "perform similar functions", so it is not stated to be complete.
• Demographic information is given with the examples age and location.

Not stated here

• What "similar functions" covers is not stated.

Use & Processing · User right or choice

With an EEA IP address, a cookie banner asks for consent and your choice is saved in a one-year cookie

The policy says that when you visit its website with an EEA IP address, a cookie banner appears asking for your consent, and you can manage your choice by clicking "manage cookie preferences" in the banner. Roblox saves your choices in a cookie with a limited effective period of one year. For more it refers to Section 7 below.

Supporting quotations

Your cookie rights in the EEA

When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner.

We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. For more information, see Section 7 below.

Qualifications & exceptions

• Applies when visiting the website with an EEA IP address.
• The consent-choice cookie lasts one year.

Not stated here

• What Section 7 adds on cookie choices is covered by the cards for that section, not this passage.
• Whether a similar consent banner appears outside the EEA is not stated here.

Use & Processing · User right or choice

On Roblox.com cookie options are in the page footer; on other sites you clear cookies to see the banner

The policy says that for Roblox.com you click the link in the footer at the bottom of the page to access your cookie options. For all other sites, it says to clear your cookies and refresh your browser so the cookie banner is displayed and you can reach its settings.

Supporting quotations

Your cookie choices

For Roblox.com, click on the link in the footer at the bottom of the page to access your cookie options. For all other sites, please clear your cookies and refresh your browser to display the cookie banner to access its settings.

Qualifications & exceptions

• The footer link applies to Roblox.com; other sites use the clear-cookies-and-refresh route.

Not stated here

• Which "other sites" are meant is not listed in this passage.

Use & Processing · User right or choice

Most browsers accept cookies by default; you can change browser settings to refuse or be warned

The policy says most web and mobile browsers automatically accept cookies, but you can change browser settings so cookies are not accepted or you are warned before a cookie is set. It lists browser company help pages (Chrome, Edge, Firefox, Safari, Android Browser, Opera) and a general cookie information website, which it says also explains how to block or delete cookies already on your device.

Supporting quotations

Most web and mobile device browsers automatically accept cookies, but you can change your browser settings so that cookies are not accepted or you are warned before a cookie is set.

Use information from browser companies to learn more about how they manage cookies:

You can also learn more about cookies by visiting https://www.allaboutcookies.org/, which also tells you how to block or delete cookies that are already on your device.

Qualifications & exceptions

• Browser settings control cookies for the browser, not only Roblox cookies.

Not stated here

• The linked browser and cookie information pages are not supplied here, so what they say is not established.

Account & Service Control · Restriction or exception

Blocking or deleting cookies might limit your experience and could stop you logging in

The policy says that by blocking or deleting cookies used, you might limit your experience of the Service, and that you might not be able to log in or experience Roblox.

Supporting quotations

By blocking or deleting cookies used, you might limit your experience of the Service. You might not be able to log in or experience the Roblox.

Qualifications & exceptions

• Stated as "might"; not a certain result.

Not stated here

• Which cookies are needed to log in is not stated in this passage.

Use & Processing · User right or choice

The EEA cookie banner and one-year choice cookie are described again under cookie choices

Under cookie choices the policy repeats that when you visit its website with an EEA IP address, a cookie banner appears asking for your consent, which you can manage by clicking "manage cookie preferences". Roblox saves your choices in a cookie with a limited effective period of one year, and refers to Section 7 below for more details.

Supporting quotations

When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. For more details see Section 7 below.

Qualifications & exceptions

• Applies when visiting the website with an EEA IP address.
• The consent-choice cookie lasts one year.

Not stated here

• What Section 7 adds is covered by the cards for that section.

Use & Processing · User right or choice

You can ask Roblox or a third party to disable advertising-related tracking, but Do Not Track signals are not honored

The policy says you can ask Roblox or a third party to disable advertising-related tracking on its websites. To disable it, Roblox or the third party may need to set an opt-out cookie on your browser, and you may need to change browser settings to accept cookies to fully disable advertising-related tracking. It says its Services do not respond to Do Not Track (DNT) signals.

Supporting quotations

To stop companies from tracking you on their websites

You can ask us or a third party to disable advertising-related tracking on our websites. To disable this tracking, we or the third party may need to set an opt-out cookie on your browser. You may need to change your browser settings to accept cookies if you want to fully disable advertising-related tracking.

Please note that our Services do not respond to Do Not Track (DNT) signals.

Qualifications & exceptions

• Applies to Roblox's websites.
• An opt-out cookie may be needed, so cookies may need to be accepted.
• Do Not Track signals are not responded to.

Not stated here

• How to ask Roblox or the third party is not described in this passage.
• Which third parties are meant is not stated.

Legal Rights & Agreement Rules · Restriction or exception

Experience and under-13 parts of the policy do not apply to Roblox corporate websites, which offer no experiences

The policy says the parts of it that are about experiences or give information about users under 13 do not apply to the corporate websites. It describes the corporate websites as corp.roblox.com, blog.roblox.com and their subdomains, which give general company information, press and career information, and other general audience information, and says they do not offer any experiences.

Supporting quotations

On our corporate websites or in job applications

The parts of this privacy policy that are about experiences or give information about users under 13 years old don’t apply to the corporate websites.

Our corporate websites give general company information to any user that visits them – they use the domain names, corp.roblox.com, blog.roblox.com, and their subdomains.

Our corporate websites do not offer any experiences.

Qualifications & exceptions

• Applies to the named corporate websites.
• Only the parts about experiences or about users under 13 are stated not to apply.

Not stated here

• Which other parts of the policy apply to the corporate websites is not spelled out in this passage.

Data Access & Collection · Company practice

Job inquiries may give Roblox your name, email and employment details, and immersive career spaces may be recorded

The policy says that if you contact Roblox about job opportunities it may ask for your name, email address and employment details, or you may send a CV or job application with this information. Roblox says it has the right to use this information to send corporate-related information or respond to the application. If you engage with Roblox in an immersive space for prospective employees, such as the Roblox Career Center, the space may be recorded in order to provide the experience.

Supporting quotations

If you contact us about job opportunities, we may ask for your name, email address and employment details.

We have the right to use this information to send you corporate-related information to you or respond to your job application.

such a space may be recorded in order to provide the experience

Qualifications & exceptions

• Applies to people who contact Roblox about job opportunities.
• Recording applies to immersive spaces for prospective employees and is stated "may".

Not stated here

• How long job application information is kept is not stated in this passage.

Sharing & Disclosure · Company commitment

Roblox shares information with service providers who may use it only for the assigned tasks, not for selling

The policy says Roblox may share your information, including Personal Information, with other companies (third-party agents, contractors or service providers) that it hires to perform services. It says these companies are only allowed to use the information to complete the relevant tasks and not for any other purpose, including selling Personal Information, and that Roblox makes sure the companies are capable of looking after the information properly. It also says Personal Information collected through the SMS program will not be shared, sold or rented to third parties.

Supporting quotations

When we share your information

We may share Personal Information where necessary

When other companies need Personal Information to provide a service on our behalf

We may share your information, including Personal Information, with other companies (known as third-party agents, contractors, or service providers). We hire these companies to perform services for us.

These companies are only allowed to use the information we share to complete the relevant tasks. They are not allowed to use the information we share for any other purpose, including selling Personal Information.

Personal Information collected through the SMS program, won’t be shared, sold or rented to third parties.

Qualifications & exceptions

• Applies to companies that provide services on Roblox's behalf.
• Providers may use the information only to complete the relevant tasks.
• The SMS program statement is a separate commitment about information collected through that program.

Not stated here

• The "SMS program" is not defined in this passage.
• How Roblox checks that providers can look after the information is not described.

Sharing & Disclosure · Company practice

Examples of companies Roblox may share information with include Persona, Google, AppsFlyer and payment providers

The policy gives examples of services it might rely on other companies to provide and examples of the companies it is likely to share information with: account integrity and security (for example Persona), analytics (Google LLC), user acquisition (AppsFlyer), community filtering and moderation, customer support, surveys and promotions (Reach3), billing and payment (Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla), and hosting and content delivery (AWS, Equinix, CenturyLink, YouTube, Vimeo).

Supporting quotations

Here are examples of the services that we might rely on other companies to provide, and examples of the companies that we are likely to share information with.

Account integrity and security services (e.g., Persona);

Analytics services (e.g., Google LLC);

User acquisition services (e.g., AppsFlyer);

Community filtering and moderation services;

Customer support services;

Surveys and promotions (e.g., Reach3);

Billing and payment services (e.g., Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla)

Hosting and content delivery services (eg, AWS, Equinix, CenturyLink, YouTube, Vimeo).

Qualifications & exceptions

• The lists are examples ("might", "likely"), not an exhaustive list of recipients.
• Some categories give no named example.

Not stated here

• Which providers actually receive which information is not stated.

Sharing & Disclosure · Company practice

Creators of experiences you use can see your names, user ID, game metrics, UGC transaction details and region

The policy says creators of the experiences you use or content you interact with have access to your username, display name, user ID, game metrics, UGC transaction details and your regional location, which Roblox bases on your IP address. It says Roblox does not share your IP address with creators. It says regional location is provided so creators can determine their player base and make sure their experiences meet the legal requirements of the country you live in.

Supporting quotations

When creators need Personal Information to improve your experience

The creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators.

We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in.

Qualifications & exceptions

• Applies to creators of the experiences you use or content you interact with.
• Regional location is based on IP address; the IP address itself is not shared.

Not stated here

• How creators may use this information beyond the stated purposes is not addressed in this passage.

Sharing & Disclosure · Permission or license

Roblox may share Personal Information for court orders, agency requests, crime prevention or legal rights

The policy says Roblox may share your Personal Information, as permitted or required by law, if it is necessary to comply with a judicial proceeding, court order or other legal process served on Roblox; if law enforcement agencies, regulators or other public agencies (including schools or children's services) request it; if Roblox believes disclosure may prevent a crime; if Roblox believes it is necessary to protect its legal rights or the legal rights of others; or if a law requires it to share the information.

Supporting quotations

For legal reasons or to help prevent a crime

We may share your Personal Information, as permitted or required by law, if:

necessary to comply with a judicial proceeding, court order, or other legal process served on Roblox

law enforcement agencies, regulators, or other public agencies (including schools or children's services) request that we share it

we believe that disclosing the information may prevent a crime

we believe it is necessary to protect our legal rights or the legal rights of others

a law requires us to share it

Qualifications & exceptions

• Stated as "as permitted or required by law".
• Several grounds depend on Roblox's own belief (crime prevention, protecting legal rights).
• Requests can come from public agencies including schools or children's services.

Not stated here

• The policy does not say whether Roblox notifies the user before sharing on these grounds.

Sharing & Disclosure · Permission or license

Roblox may share the contents of your communications with authorities for threats to life and under online safety laws

The policy says Roblox may also share the contents of your communications, as permitted or required by law: to law enforcement or judicial authorities to address a threat to the life or safety of a person, including (but not limited to) where consistent with its obligations under the Digital Services Act, Article 18; when required by law in response to governmental regulatory requests, such as information notices issued under the UK Online Safety Act; and when required by laws governing online safety, such as the Australian Online Safety Act. The policy names these laws but does not set out their content.

Supporting quotations

We may also share the contents of your communications as permitted or required by law:

to law enforcement or judicial authorities to address a threat to life or safety of a person, including (but not limited to) where consistent with Roblox's obligations under the Digital Services Act, Article 18

when required by law in response to governmental regulatory requests, such as Information notices issued under the UK Online Safety Act

when required by laws governing online safety, such as the Australian Online Safety Act

Qualifications & exceptions

• Stated as "as permitted or required by law".
• The Digital Services Act reference is "including (but not limited to)", so the list is not complete.
• The UK and Australian laws are given as examples ("such as").

Not stated here

• What the named laws require is not supplied here and is not described by this card.

Sharing & Disclosure · Permission or license

Roblox may share Personal Information or communication contents if it believes sharing would support safety or security

The policy says Roblox may share your Personal Information or the contents of your communications if it believes that sharing would help an investigation into public safety or a violation of its Terms of Use, protect the safety of Roblox users or others, reduce risk to user safety or security (or if collaborating with others is necessary to protect users), or help protect the security or integrity of its Services.

Supporting quotations

To support safety and security

We may share your Personal Information or the contents of your communications if we believe that sharing would:

help an investigation into public safety or a violation of our Terms of Use

protect the safety of Roblox users or others

reduce risk to user safety or security, or if collaborating with others is necessary to protect users

help to protect the security or integrity of our Services

Qualifications & exceptions

• Sharing depends on Roblox's belief that it would achieve the listed aim.
• Covers both Personal Information and contents of communications.

Not stated here

• Who the information may be shared with under this passage is not stated.

Sharing & Disclosure · Permission or license

Roblox may share information to take precautions against legal responsibility or protect its rights

The policy says Roblox may share your information if it believes that disclosing the information will allow it to take precautions against taking legal responsibility (liability) or to protect its rights.

Supporting quotations

If we need to protect ourselves against legal responsibility

We may share your information if we believe that disclosing the information will allow us to take precautions against taking legal responsibility (liability) or to protect our rights.

Qualifications & exceptions

• Depends on Roblox's belief.

Not stated here

• Who receives the information is not stated.

Sharing & Disclosure · Permission or license

Your information may pass to a buyer or in an insolvency; where law requires, Roblox will notify you and ask consent

The policy says Roblox may hand over rights to access your information, including Personal Information, as part of a merger, acquisition, sale of assets or similar transaction, or if information is handed over as a business asset in an insolvency, bankruptcy or receivership. It says that where required by law, Roblox will notify you and ask you to consent to such sharing.

Supporting quotations

If there is a transfer of rights in our business e.g., if we sell our business

We may hand over rights to access your information, including Personal Information:

as part of a merger, acquisition, sale of assets, or similar transaction

if information is handed over as a business asset in an insolvency, bankruptcy, or receivership

Where required by law, we will notify you and ask you to consent to such sharing.

Qualifications & exceptions

• Notice and consent apply only "where required by law".

Not stated here

• In which places the law requires notice and consent is not stated in this passage.

Sharing & Disclosure · Company practice

Roblox may disclose contact identifiers, demographics and device IDs to advertising and measurement companies

The policy says Roblox may disclose information collected from or about you to third-party advertising companies and/or advertising measurement companies to select and display ads on Roblox, or to measure and improve advertising effectiveness. It says that, in accordance with applicable law, it provides choices about whether data is disclosed for this purpose. The data disclosed includes contact identifiers, characteristics or demographics, and device identifiers.

Supporting quotations

We may disclose Personal Information to third parties

For Advertising Purposes

Roblox may disclose information collected from or about you with third-party advertising companies and/or advertising measurement companies to select and display advertisements to you on Roblox, or measure and improve advertising effectiveness.

In accordance with applicable law, we provide our users with choices about whether data is disclosed for this purpose.

Contact identifiers

Characteristics or demographics

Device identifiers

Qualifications & exceptions

• Choices are provided "in accordance with applicable law".
• The data list says "includes", so it is not stated to be complete.

Not stated here

• The passage does not say whether this list applies to users under 18 in the same way; a later sentence limits disclosure for personalized advertising for those users.

Cross-references

• narrows (model-proposed): Ad data choices are in privacy settings; under-18s' Personal Information is not disclosed to direct personalized ads — The disclosure of data to advertising companies is narrowed by the statement that no Personal Information of users under 18 is disclosed for directing personalized advertising.

Sharing & Disclosure · Company practice

Advertising companies may receive device identifiers such as IP address or device ID when you reach Roblox through an ad

The policy says Roblox partners with third-party advertising companies such as ad server companies and ad networks to advertise Roblox on other websites and services. If you interact with content or reach Roblox through a link in an advertisement, Roblox or its service providers may give these advertising companies identifiers from your device, such as an IP address or device ID.

Supporting quotations

We also partner with third-party advertising companies such as ad server companies and ad networks to advertise Roblox on other websites and services. If you interact with content or reach Roblox through a link in an advertisement, we or our service providers may give these third-party advertising companies identifiers from your device, such as an IP address or device ID.

Qualifications & exceptions

• Applies when you interact with content or reach Roblox through a link in an advertisement.
• Identifiers are given as examples ("such as").

Not stated here

• Whether other data is given to these companies is not stated in this passage.

Sharing & Disclosure · User right or choice

Ad data choices are in privacy settings; under-18s' Personal Information is not disclosed to direct personalized ads

The policy says you can exercise choices about data processing for the advertising purpose on your account's privacy settings page, and that depending on where you live you may have additional rights, with region-specific information in Section 7. It says Roblox does not disclose any Personal Information from users under 18 for the purposes of directing personalized advertising. When you interact with an ad on Roblox, it says it works with partners to produce aggregated measurement information.

Supporting quotations

You can exercise choices about data processing for this purpose by visiting your account’s privacy settings page

Depending on where you live, you may have additional rights that apply. For region-specific information, please visit Section 7 of this policy.

We do not disclose any Personal Information from users under 18 years old for the purposes of directing personalized advertising.

When you interact with an ad on Roblox, we work with partners to produce aggregated measurement information.

Qualifications & exceptions

• The under-18 statement is limited to disclosure "for the purposes of directing personalized advertising".
• Additional rights depend on where you live.

Not stated here

• Whether under-18 data goes to partners for non-personalized advertising or measurement is not stated beyond the aggregated measurement sentence.

Cross-references

• narrowed by (model-proposed): Roblox may disclose contact identifiers, demographics and device IDs to advertising and measurement companies — The disclosure of data to advertising companies is narrowed by the statement that no Personal Information of users under 18 is disclosed for directing personalized advertising.

Charges & Financial Obligations · Company practice

Roblox and a Commerce Provider may exchange purchase information; what you give the provider is collected by it

The policy says that if you directly interact with a Commerce Provider to purchase a Commerce Product on Roblox, Roblox and the Commerce Provider may need to exchange information about your purchase to fulfill the transaction, including a transaction identifier that lets each party confirm certain information such as whether a purchase has been completed. It says any information you give directly to the Commerce Provider to complete a transaction is independently collected by that provider and subject to its terms and policies.

Supporting quotations

Roblox Commerce

If you directly interact with a Commerce Provider to purchase a Commerce Product(s) on Roblox, Roblox and the Commerce Provider may need to exchange information about your purchase in order to fulfill the transaction.

Any information you provide directly to the Commerce Provider in order to complete a transaction is independently collected by the Commerce Provider and will be subject to the Commerce Provider’s applicable terms and policies.

Qualifications & exceptions

• Applies when you interact directly with a Commerce Provider to buy a Commerce Product.
• Information you give the provider is independently collected by the provider.

Not stated here

• "Commerce Provider" and "Commerce Product" are not defined in this passage; the Roblox Dictionary is linked but not supplied.
• The Commerce Provider's terms and policies are not supplied.

Sharing & Disclosure · Permission or license

Roblox may share data that does not identify you for reporting, any business or marketing purpose and usage insight

The policy says that in some circumstances Roblox shares data that does not identify you, for example to comply with reporting requirements, for any business or marketing purposes, and to help Roblox and others understand how, when and why users visit its sites and use Roblox. It says it may share non-identifying data of all users regardless of their age.

Supporting quotations

We may share information that does not identify you

In some circumstances, we share data that doesn’t identify you, for example:

To comply with reporting requirements

For any business or marketing purposes

To help us and others understand how, when, and why users visit our sites and use Roblox.

We may share non-identifying data of all users regardless of their age.

Qualifications & exceptions

• Applies to data that "doesn't identify you".
• The purpose "any business or marketing purposes" is broad.
• Applies to users of any age.

Not stated here

• How Roblox decides data does not identify a person is not described in this passage.

Legal Rights & Agreement Rules · Restriction or exception

Roblox takes steps against sharing Personal Information in chats but is not responsible for what you share yourself

The policy says Roblox takes steps to prevent users from sharing Personal Information via chats, forums, messages or similar ways of communicating on Roblox. It reminds you that anyone who uses these features can see information you share this way, and says Roblox is not responsible for how your Personal Information is used if you shared it yourself.

Supporting quotations

We’re not responsible if you share your own Personal Information

Roblox takes steps to prevent users from sharing Personal Information via chats, forums, messages, or similar ways of communicating on Roblox.

Remember that anyone who uses these features will be able to see information that you share in this way. We are not responsible for how your Personal Information is used if you shared it yourself.

Qualifications & exceptions

• Applies to Personal Information you share yourself through chats, forums, messages or similar features.
• Roblox describes "steps" to prevent sharing without promising that it succeeds.

Not stated here

• Which steps Roblox takes is not described in this passage.

Security & Safeguards · Company commitment

Roblox uses reasonable security efforts, gives no guarantee and limits liability for unintentional disclosure

The policy says Roblox has security measures intended to protect Personal Information and other sensitive information under its control from loss, misuse or alteration, and that although it cannot guarantee such events will never occur it uses reasonable efforts to prevent them. It says sending or storing information on the internet is not 100% secure, so it cannot guarantee the security of information you share with it, and, to the fullest extent permitted by applicable law, it does not accept liability for unintentional disclosure.

Supporting quotations

Security measures

We have security measures that are intended to protect any Personal Information or other sensitive information under our control from loss, misuse, or alteration. Though we cannot guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it.

Sending or storing information on the Internet is not 100% secure, so we can’t guarantee the security of any information you share with us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

Qualifications & exceptions

• Roblox commits to reasonable efforts, not to a result.
• The liability disclaimer applies to unintentional disclosure and only "to the fullest extent permitted by applicable law".

Not stated here

• The specific security measures are not listed.

Security & Safeguards · Company commitment

Roblox may email you about security and privacy and will notify you of a data breach as the law requires

The policy says Roblox may send emails or other messages about security, privacy and account management, and that if it learns of an incident that may qualify as a data breach under the law it will notify you in accordance with the law.

Supporting quotations

We’ll tell you if your privacy is at risk

We may send you emails or other messages about security, privacy, and account management. If we learn about an incident that may qualify as a data breach under the law, we will notify you in accordance with the law.

Qualifications & exceptions

• Breach notice is "in accordance with the law" and applies to incidents that may qualify as a data breach under the law.

Not stated here

• How quickly, and in which places, Roblox must notify is not stated.

Retention & Deletion · Company commitment

Roblox keeps Personal Information as long as needed for its purposes, then de-identifies or deletes it

The policy says Roblox may keep your Personal Information for specific purposes as long as it needs it to fulfill those purposes, sometimes even if you have stopped using the Services. When it no longer requires the information, it says it will de-identify or delete it.

Supporting quotations

How long we keep your information

We may keep your Personal Information for specific purposes as long as we need it to fulfill those purposes, sometimes even if you’ve stopped using Roblox’s Services. When we no longer require your Personal Information, we will de-identify or delete the information.

Qualifications & exceptions

• Retention lasts as long as needed for the specific purposes; this may continue after you stop using the Services.

Not stated here

• No fixed retention periods are given in this passage.

Cross-references

• referred to by (model-proposed): Persistent identifiers are kept while you have an account, and up to two years after deletion for safety — The data retention statement for persistent identifiers sits within the under-13 part, while the general retention passage in the looking-after-information part covers Personal Information more broadly; neither states fixed periods for all categories.

Retention & Deletion · Company practice

Roblox may keep billing and account history, safety information and information needed for legal reasons

The policy lists reasons Roblox may need to keep information. To resolve problems it keeps billing information and transaction histories for billing disputes or inquiries, and user account history to solve customer service issues and to provide, improve and develop its service. To make services safer it may keep information that helps make the Service safer and more secure, such as to stop bad actors misusing Roblox. For legal reasons it may keep information for establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing agreements, exercising rights or complying with legal obligations.

Supporting quotations

For resolving problems

We keep billing information and transaction histories so that we can resolve billing disputes or inquiries.

We keep user account history to solve any customer service issues and to provide, improve, and develop our service.

To make our services safer

We may keep information if it will help us make our Service safer and more secure, such as to stop bad actors who try to misuse Roblox.

For legal reasons

We may keep information for legal reasons, like establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, exercising our rights, or complying with legal obligations.

Qualifications & exceptions

• Billing and account history are kept to resolve problems.
• The safety and legal reasons are stated as things Roblox "may" keep information for.
• "Pursuing legitimate business purposes" is a broad legal-reason ground.

Not stated here

• How long information is kept for each reason is not stated.

Retention & Deletion · Restriction or exception

Other users may keep publicly shared content and virtual items you give them

The policy says other users may keep publicly shared content and virtual items on the platform, giving the example that if you create a virtual shirt and sell it to another user, the shirt will be kept on the platform because the other user now possesses it.

Supporting quotations

Letting other users keep your information

Other users may keep publicly shared content and virtual items on our platform (e.g., if you create a virtual shirt and then sell it to another user, the virtual shirt will be kept on the platform because the other user now possesses it).

Qualifications & exceptions

• Covers publicly shared content and virtual items other users possess.
• The shirt is an example.

Not stated here

• Whether other kinds of content stay after account deletion is not stated in this passage.

Sharing & Disclosure · Company practice

Information is stored on US servers and may be transferred abroad, with reasonable steps to protect privacy rights

The policy says Roblox is based in the United States and sends information it collects from you to its secure servers in the US, where it stores and uses it. It may also transfer information to its other offices and to the third parties mentioned in Section 4 of the policy, which might be outside your region, and its agents or contractors may also use your information. It says the data protection laws of the US or other countries may not be equivalent to those where you live. Wherever it transfers Personal Information, Roblox says it will take reasonable steps so that your privacy rights continue to be protected, and, if required by applicable legislation, it relies on a valid international data transfer mechanism.

Supporting quotations

Where we store your information

Roblox is based in the United States. We send information we collect from you to our secure servers in the U.S. where we store and use it.

We may also transfer information that we collect from you to our other offices and to the third parties mentioned in Section 4 of this Policy – these might be outside your region.

The data protection laws of the U.S. or other countries may not be equivalent to those where you live.

Wherever we transfer your Personal Information, we will take reasonable steps so that your privacy rights continue to be protected. If required by applicable legislation, we rely on a valid international data transfer mechanism to enable cross-border data transfers.

Qualifications & exceptions

• Information is sent to servers in the US.
• Transfers may be outside your region.
• A transfer mechanism is used only if required by applicable legislation.

Not stated here

• Which transfer mechanism is used is not stated.
• Which other offices receive information is not stated.

Legal Rights & Agreement Rules · Company commitment

Roblox updates the policy from time to time and gives notice of major changes before they take effect

The policy says Roblox updates it at times, so you should review the page regularly, and that it always publishes the date of the latest version at the bottom of the page. For major changes it says it will let you know by email (if it has your email address or a parent's or legal guardian's) or by a prominent notice on the website or in the app before the change becomes effective. If required by law, it will obtain your consent or a parent's or guardian's consent if changes involve new material uses of Personal Information not previously disclosed in the policy.

Supporting quotations

Privacy Policy Changes and Updates

We update this Privacy Policy at times, so you should review this page regularly. We always publish the date of the latest version at the bottom of this page.

If we make any major changes, we will let you know by email (if we have your email address or a parent’s or legal guardian’s email address) or by showing a prominent notice on this website or in app prior to the change becoming effective.

If required by law, we will obtain your consent or the consent of a parent or legal guardian if any of these changes involve new material uses of your Personal Information not previously disclosed in this Privacy Policy.

Qualifications & exceptions

• Notice applies to "major" changes.
• Notice is by email if Roblox has an address, or a prominent notice on the website or in app.
• Consent is sought only if required by law and the change involves new material uses.

Not stated here

• What counts as a "major" change is not defined.
• The date at the bottom of the page is not part of the supplied text.

Account & Service Control · User right or choice

Where you live may give you extra choices or rights; requests go through the Customer Support Form

The policy says that if you live in certain regions you may have additional choices about your Personal Information or rights that apply to data processing, and that this section contains additional information based on where you live. To exercise rights or make another request, including asking Roblox to make another request about your Personal Information, you fill in the Customer Support Form. If you are under 13 a parent or guardian should fill out the form.

Supporting quotations

Additional information based on where you live

If you live in certain regions, you may have additional choices about your Personal Information or rights that apply to data processing. This section contains additional information based on where you live.

If you want to exercise your rights or make another request about your Personal Information, or if you want us to make another request about your Personal Information, please fill in the Customer Support Form. If you’re under 13 years old, please have your parent or guardian fill out the form.

Qualifications & exceptions

• Additional choices or rights depend on where you live.
• Requests are made through the Customer Support Form; under-13s need a parent or guardian to complete it.

Not stated here

• What the additional rights are for each region is shown in the following cards for this section; the introduction itself names none.
• The Customer Support Form is linked but its text is not supplied here.

Legal Rights & Agreement Rules · Context

US and Korea residents are pointed to separate addenda that are not supplied here

In the location-specific section, the policy sends US residents to the US State Privacy Policy Addendum and Korean residents to the Privacy Policy Addendum for Users in Republic of Korea for more information. The text of those addenda is not part of this source.

Supporting quotations

If you live in the United States

If you live in the United States, please visit our US State Privacy Policy Addendum

If you live in the Republic of Korea

If you’re in Korea, more information is located in the Privacy Policy Addendum for Users in Republic of Korea

Qualifications & exceptions

• Applies to users living in the United States or the Republic of Korea.

Not stated here

• What either addendum provides is not supplied in this source, so these rights are not described here.

Cross-references

• referred to by (model-proposed): Korea and US state privacy rights are in separate addenda not supplied here — The general contact section and the location section both point to the same US State and Korea addenda, whose text is not supplied.

Legal Rights & Agreement Rules · Context

For EEA, UK and Swiss residents the policy lists categories of Personal Information and purposes with legal bases

For people living in the European Economic Area, the United Kingdom or Switzerland, the policy says that in the course of visiting its websites and apps or using its services and products it may process listed Personal Information subject to the legal bases mentioned. The lists of categories, purposes and legal bases follow in the next entries of this section.

Supporting quotations

If you live in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland

Categories of Personal Information and Data Processing Purposes

In the course of visiting our websites and apps, and/or using our services and products, we may process the following Personal Information subject to the legal bases mentioned below:

Qualifications & exceptions

• Applies to people living in the EEA, UK or Switzerland.
• Processing is "subject to the legal bases mentioned below".

Not stated here

• The categories and bases themselves are set out in the entries that follow, not in this introduction.

Legal Rights & Agreement Rules · Company practice

EEA/UK/Swiss list: username and password are processed to create your account, on a contract basis

In the list for people living in the EEA, UK or Switzerland, the policy says Roblox processes your username and password to create your account and gives as the basis for processing Article 6 sec. 1 sent. 1 lit. b ("performance of a contract").

Supporting quotations

Setting up a Roblox account

Username and password to create your account. The basis for processing this Personal Information is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”).

Qualifications & exceptions

• Applies under the heading for people living in the EEA, UK or Switzerland.
• The legal basis is stated as "performance of a contract".

Not stated here

• Which law the Article numbering refers to for the UK and Switzerland is not spelled out in this passage.

Legal Rights & Agreement Rules · Company practice

EEA/UK/Swiss list: email and verification information rest on contract and a legitimate interest in child safety

The list says Roblox processes email addresses and other information you provided for added verification and/or to enable certain features, on the bases Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and f ("legitimate interest") GDPR. It states that Roblox has a legitimate interest in providing a safe and secure Service, especially to protect children.

Supporting quotations

Email addresses and other information you provided us with for added verification and/or to enable certain features. The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”) GDPR. Roblox has a legitimate interest in providing a safe and secure Service, especially to protect children.

Qualifications & exceptions

• Two bases are given: contract and legitimate interest.
• The legitimate interest stated is a safe and secure Service, especially to protect children.

Not stated here

• Which features need "other information" is not specified.

Legal Rights & Agreement Rules · Company practice

EEA/UK/Swiss list: phone number use rests on contract and legitimate interest; friend recommendations on consent

The list says that if you choose to provide a phone number, Roblox uses it for security and account access purposes, to allow login via mobile and to recover a lost or forgotten password. You authorize your wireless carrier to use or disclose information about your account and device to Roblox or its service provider for the duration of your business relationship, solely to help identify you or your device and to prevent fraud. The stated legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract") and f ("legitimate interest"), the legitimate interest being enabling mobile use, ensuring security and preventing fraud. With your consent Roblox may use your phone number to recommend you as a friend, which rests on Article 6 sec. 1 sent. 1 lit. a GDPR ("consent").

Supporting quotations

If you choose to provide a phone number, we will use the phone number for security and account access purposes, which will allow you to log in via mobile and recover a lost or forgotten password.

The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”) and f (“legitimate interest”) GDPR. We have a legitimate interest in enabling you to use our Services via your mobile device, ensuring security, and preventing fraud.

Additionally, with your consent, we may use your phone number to recommend you as a friend to others using Roblox. The legal basis for friend recommendations and discoverability based on your phone number is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”).

Qualifications & exceptions

• Providing a phone number is a choice.
• Friend recommendations and discoverability based on your phone number require consent.
• Carrier authorization is limited to identifying you or your device and preventing fraud.

Not stated here

• Which law the Article numbering refers to for the UK and Switzerland is not spelled out in this passage.

Charges & Financial Obligations · Company practice

EEA/UK/Swiss list: billing data rests on contract and legitimate interest; saved card data stays with the partner

The list says Roblox collects billing and payment information when you participate in Developer Exchange or purchase Robux or premium subscriptions for yourself or another user, including name, billing address, credit card or other payment information. If you save information such as a credit card number with a third-party payment provider, the information is stored with the partner and not by Roblox. If you buy Robux for another user Roblox collects contact information to communicate about the transaction. The basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). Roblox may also collect billing addresses and retain transaction details and purchase and payment history, on the basis of its legitimate interest in performing billing and resolving inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest").

Supporting quotations

Purchases on Roblox

Billing and payment information, when you participate in Developer Exchange or purchase Robux or premium subscriptions on behalf of yourself or another user, including your name, billing address, credit card or other payment information and billing information.

You may choose to save information such as your credit card number through a third-party payment provider; in such cases the information is not stored by Roblox; it is stored with the third-party partner.

We may also collect billing addresses and retain transaction details and purchase and payment history. The legal basis for processing this Personal Information is our legitimate interest in being able to perform billing and resolve inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Qualifications & exceptions

• Two bases: contract for the purchase, legitimate interest for retaining billing addresses, transaction details and payment history.
• Saved card information is stored with the third-party partner, not Roblox.

Not stated here

• How long transaction details and payment history are retained is not stated in this passage.

Use & Processing · Company practice

EEA/UK/Swiss list: posts are monitored on a legitimate-interest basis, and other users can read what you post

The list says Roblox processes comments or messages you post or transmit through public chats, forums, group walls and personal posts to monitor, filter and moderate them so it can remove profanity, Personal Information and other inappropriate conversations, and may use pre-filtered comments and messages for other purposes such as training and improving its filter technology. The stated basis is Roblox's legitimate interest in defending itself from possible liability claims from unlawful comments, Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest"). It warns that Personal Information you submit in forums and similar means is available to anyone with access, including other users, and could be read, collected or used by other users, including to send unsolicited messages.

Supporting quotations

Posting content

We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, Personal Information, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology.

The legal basis for this processing activity is Roblox’s legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Please note that any Personal Information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The Personal Information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.

Qualifications & exceptions

• Basis stated is legitimate interest.
• Training and improving filter technology uses pre-filtered comments and messages.

Not stated here

• Whether the "pre-filtered" use is limited to filter technology is not stated; the passage gives "other purposes such as" training and improving the filter.

Legal Rights & Agreement Rules · Company practice

EEA/UK/Swiss list: customer service contact details are processed on a contract basis

The list says Roblox processes information relating to contacting its customer service, for example when you report a problem or submit questions, concerns or comments: your email address, your name and information about your inquiry, in order to respond, fulfill requests or provide other customer support. It says this is based on Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"), depending on the initial purpose for contacting customer support.

Supporting quotations

Asking questions or getting technical support

We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support.

This processing activity is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.

Qualifications & exceptions

• The contract basis depends on the initial purpose for contacting customer support.

Not stated here

• What other basis applies where the contract basis does not is not stated.

Linking & Identification · Company practice

EEA/UK/Swiss list: Roblox may access linked social account information; deleting Roblox may cut off third-party sign-ins

The list says that for social media links you add to your account, certain information from your social media accounts may be accessed by or shared with Roblox, on the basis Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"). In the same item it says that if you use your Roblox credentials to sign in to a third-party website or service and later delete your Roblox account, you may lose access to that website or service. This places the sign-in sentence within the social media links item for this list.

Supporting quotations

Using Roblox Features

Social media links you add to your account. When you use these features, certain information from your social media accounts may be accessed by or shared with Roblox. The legal bases for this processing activity are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”).

If you use your Roblox credentials to sign in to a third-party website or service, and later delete your Roblox account, you may lose access to such third-party website or service.

Qualifications & exceptions

• Information "may be accessed by or shared with" Roblox.
• Losing third-party access is stated as "may".

Not stated here

• Which information from social media accounts is accessed is not stated.

Cross-references

• qualified by (model-proposed): Users 13 and older can add social media links; Roblox may see information about those accounts — The general passage leaves unclear whether the sign-in sentence belongs to the social links feature; the EEA/UK/Swiss list puts the same sentence in the social media links item.

Use & Processing · Company commitment

EEA/UK/Swiss list: no training on EEA private server voice chat; other voice training only with consent

The list says that when you use audio features Roblox may collect, process and store your audio recording to enable features like voice services and make Roblox safer, on the bases Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and f ("legitimate interest"). It says Roblox will not engage in training or product improvement with private server voice chat recordings of EEA users, and that with your consent it will use voice recordings to inform training and product improvement, on the basis Article 6 sec. 1 sent. 1 lit. a ("consent"). The "will not" commitment is worded for EEA users; the passage does not extend it to UK or Swiss users.

Supporting quotations

When you use audio features from Roblox, we may collect, process and store your audio recording to enable features like voice services and make Roblox safer.

We will not engage in training or product improvement with private server voice chat recordings of EEA users.

With your consent, we will use voice recordings to inform training and product improvement. The basis for processing this Personal Information for training and product improvement is Article 6 sec. 1 sent. 1 lit. a (“consent”).

Qualifications & exceptions

• The commitment not to train on private server voice chat recordings is stated for EEA users.
• Training and product improvement from voice recordings requires consent.

Not stated here

• Whether UK and Swiss users have the same private server commitment is not stated.
• Whether users in these regions can withdraw consent is not stated in this passage.

Cross-references

• qualified by (model-proposed): Location-specific rules in Section 7 override the general Sections 1-5 — The conflict rule makes the location-specific Section 7 statements prevail over the general sections where they conflict, which bears on how the EEA/UK/Swiss audio statement relates to the general audio statement.
• contrast (model-proposed): Voice and audio you use is monitored, collected, used and stored for voice chat, safety, training and screen recordings — The general audio passage says audio may be used, in accordance with applicable law, to inform training and product improvement. The EEA/UK/Swiss list says Roblox will not train on private server voice chat recordings of EEA users and uses voice recordings for training only with consent. The cards report both without deciding how they combine; Section 7 prevails on conflict for the locations it covers.

Data Access & Collection · Company practice

EEA/UK/Swiss list: location tracking for users 13+ rests on contract; personalized ads and content are examples

In the list for the EEA, UK and Switzerland, the policy says that when you request or agree to location-based services (users 13 and older), Roblox may collect and track geolocation information to offer services that depend on knowing where you are, with examples of personalizing content or personalized advertising for users 18 and older. It collects this using an identifier on your device or browser so it can recognize you when you return. To stop collection you can update device settings, stop using the service, or uninstall the mobile apps. The stated basis is Article 6 sec. 1 sent. 1 lit. b ("performance of a contract").

Supporting quotations

When you request or agree to location-based services (users 13 years old and older), we may collect and track geolocation information so that we can offer services that depend on us knowing where you are. Examples are personalizing content or personalized advertising for users 18 years old and older.

We collect this information by using an identifier on your device or browser so that we can recognize you each time you return. To stop us collecting your location information, you can update your device settings, stop using the service, or uninstall our mobile apps.

The basis for processing this Personal Information is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”).

Qualifications & exceptions

• Applies when you request or agree to location-based services; users 13 and older.
• Personalized advertising is given as an example for users 18 and older.

Not stated here

• The passage does not say how an EEA, UK or Swiss user's consent is recorded for location services.

Data Access & Collection · Company commitment

EEA/UK/Swiss list: VR movement information is collected to replicate your movement, not stored, on a contract basis

The list says that if you join experiences on a VR platform, Roblox collects your physical movement information in order to replicate your movement in the experience. It says the information is only used to provide the Service and is not stored. The basis is Article 6 sec. 1 sent. 1 lit. b ("performance of a contract").

Supporting quotations

If you join our experiences on a VR platform, we will collect your physical movement information in order to replicate your movement in the experience. This information is only used to provide the Service and is not stored.

Qualifications & exceptions

• Applies when you join experiences on a VR platform.
• Use is stated to be only to provide the Service; no storage.

Not stated here

• Whether the VR platform provider keeps this information is not addressed.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: Creator Event data goes to the third-party platform hosting the event

The list says that if you join a virtual event hosted by a Creator, data such as your username, email and Roblox user ID may be shared with the third-party platform that hosts events, to allow you to log in to the experience. Your activity during a Creator Event is subject to that platform's privacy policy as well as the Roblox Community Standards. The bases are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") to join an event and f ("legitimate interest") to support the security and integrity of the service.

Supporting quotations

If you join a virtual event hosted by a Creator, data such as your username, email, and Roblox user ID may be shared with the third-party platform that hosts events. Such data is used to allow you to log in to the experience.

Your activity during a Creator Event is subject to the third party platform’s privacy policy as well as the Roblox Community Standards

The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) to join an event and f (“legitimate interest”) GDPR to support the security and integrity of our service.

Qualifications & exceptions

• The data listed is introduced by "such as".
• The third-party platform's privacy policy governs your activity during the event.

Not stated here

• The third-party platform's privacy policy is not supplied here.
• The Roblox Community Standards are linked but not supplied here.

Data Access & Collection · Company practice

EEA/UK/Swiss list: camera and upload content is kept only as long as needed; ID verification rests on consent

The list says that for features that require your camera or let you upload content containing your Personal Information, including photos or video, Roblox will collect, process and store that content only for as long as needed to accomplish the purpose of the feature, on the basis Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"). For certain uploads, such as ID verification, it says it processes the data you upload on the basis of consent, Article 6 sec. 1 sent. 1 lit. a or Article 9 sec. 2 lit. a ("consent"). It refers to a Roblox Facial Animation Privacy Notice and a Roblox Facial Media Capture Privacy Notice.

Supporting quotations

we will collect, process, and store that content only for as long as needed to accomplish the purpose of the feature

For certain uploads, such as ID verification, Roblox processes data you upload on the basis of consent, Article 6 sec. 1 sent. 1 lit. a or Article 9 sec. 2 lit. a (“consent”).

Qualifications & exceptions

• Content is kept only for as long as needed for the feature's purpose.
• ID verification and similar certain uploads rest on consent.

Not stated here

• The two privacy notices are linked but their text is not supplied here.
• Which uploads other than ID verification count as "certain uploads" is not listed.

Data Access & Collection · Company commitment

EEA/UK/Swiss list: other features for users who are not children will show what is collected at the time of collection

The list says information required for other features or activities, which may be available to users other than children, may be offered from time to time, and you may be able to submit or upload Personal Information with them. It says the data collected and its intended uses will be evident at the time of data collection, on the basis Article 6 sec. 1 sent. 1 lit. b ("performance of a contract").

Supporting quotations

Information required for other features or activities, which may be available to our users other than children. We may offer other features or activities on our Services from time to time, and you may be able to submit or upload Personal Information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection.

Qualifications & exceptions

• Applies to features or activities available to users other than children.

Not stated here

• The features and the data they collect are not listed in the policy.

Data Access & Collection · Company practice

EEA/UK/Swiss list: Contact Importer shares your contacts' names and numbers with Roblox, on a contract basis

The list says that if you opt in to the Contact Importer feature you consent to sharing with Roblox the first and last names and phone numbers of the contacts in your address book on your mobile phone, either when you register for the Service or otherwise, to help you connect with friends. The stated legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract").

Supporting quotations

If you opt-in to the Contact Importer feature, you consent to sharing with Roblox the first and last names and phone numbers of your contacts in your address book on your mobile phone, either at the time you register for our Service or otherwise. We do so to help you connect with your friends on our Service.

Qualifications & exceptions

• Opt-in.
• Sharing may happen at registration or at another time.

Not stated here

• This passage does not repeat the age limit or retention statement given in the general Contact Importer description.

Use & Processing · Company practice

EEA/UK/Swiss list: interaction data, game state and recommendations rest on contract and legitimate interest

The list says that to improve your experience and support safety, Roblox collects information about how you interact with the Services and connects it with your account. Examples it gives: a user's game state to detect Terms violations; behavior when you interact with your device for security and safety; information from your search history to give similar recommendations; and sharing your username and transaction details with the UGC creator or subsequent owners if you acquire a limited item or transact in UGC. The bases are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and f ("legitimate interest"), and it may use interaction data for safety or moderation on the basis of legitimate interest.

Supporting quotations

To improve your experience and support our safety efforts, we collect information about how you interact with the Services and we connect this information with your account.

collect information from your search history to give you similar recommendations

share information like your username and transaction details to the UGC creator or subsequent owners, if you acquire a limited item if you purchase, share, trade, or otherwise engage in a transaction involving UGC.

We may use data collected from your interaction with our experiences for safety or moderation purposes on the basis of Article 6 sec. 1 sent.1 lit. f ("legitimate interest").

Qualifications & exceptions

• The items are introduced by "for example", so they are not stated to be complete.
• Safety or moderation use rests on legitimate interest.

Not stated here

• This list names "search history" as a recommendation input; the general description names the games you play.

Cross-references

• contrast (model-proposed): Roblox collects information about how you interact with the Services and links it to your account — The general interaction passage names the games you are playing as a recommendation input; the EEA/UK/Swiss list (and Brazil list) names search history. The cards report both without deciding whether they describe the same data.

Data Access & Collection · Company practice

EEA/UK/Swiss list: voluntary research and surveys rest on consent

The list says that when you respond to or take part in voluntary research, surveys or studies, these may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences, and may ask for Personal Information. The stated legal basis is Article 6 sec. 1 sent. 1 lit. a GDPR ("consent").

Supporting quotations

Competitions, promotions, and research

When you respond to or participate in voluntary research or surveys or studies. These surveys may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for Personal Information. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”).

Qualifications & exceptions

• Applies to voluntary research, surveys or studies.
• The basis is consent.

Not stated here

• Who runs the research is not stated in this passage.

Data Access & Collection · Company practice

EEA/UK/Swiss list: contest and promotion contact details are processed for prize fulfillment on a contract basis

The list says that for contests, competitions, sweepstakes, giveaways, prize draws or other promotions it runs or sponsors, Roblox may process certain contact information (such as your name, email address and/or phone number) for prize fulfillment, as well as other information or content needed for the specific promotion. The stated legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract").

Supporting quotations

We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion.

Qualifications & exceptions

• Applies to promotions Roblox runs on its Service or sponsors.
• Contact details are listed "such as".

Not stated here

• The passage does not mention sharing with gift card providers or publishing winners, which the general description covers.

Use & Processing · Company practice

EEA/UK/Swiss list: personalized ads rest on consent and are not shown to under-18s; other ads on legitimate interest

The list says Roblox processes Personal Information to personalize the ads you see, using information it collects and receives from partners to decide which ads to show. To the extent this involves processing Personal Information and displaying personalized ads, the stated legal basis is Article 6 sec. 1 sent. 1 lit. a GDPR ("consent"). It says Roblox does not show personalized ads to users under 18. It processes Personal Information to display non-personalized ads on the basis Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest").

Supporting quotations

Advertising

We process Personal Information to personalize the ads you see on Roblox. We use information we collect and receive from partners to decide which ads to show you on Roblox.

the legal basis for the processing is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”). We do not show personalized ads to users under the age of 18 on Roblox.

We process Personal Information to display non-personalized ads on Roblox. To the extent these practices involve the processing of Personal Information, the legal basis for processing is Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Qualifications & exceptions

• Personalized ads: consent basis; not shown to users under 18.
• Non-personalized ads: legitimate interest basis.

Not stated here

• What counts as information "received from partners" is not stated.

Cross-references

• qualified by (model-proposed): Under-18s see only nonpersonalized ads; users 18 and over see personalized ads, with consent where required — The general rule that users 18 and older see personalized ads with consent where required is given a consent basis in the EEA/UK/Swiss list, and both say users under 18 see no personalized ads.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: ads shown with partners rest on consent if personalized and legitimate interest if not

The list says Roblox also may work with partners to directly show you ads on Roblox. To the extent this involves processing Personal Information to display personalized ads, the stated legal basis is Article 6 sec. 1 sent. 1 lit. a GDPR ("consent"); to display non-personalized ads, it is Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest").

Supporting quotations

Roblox also may work with partners to directly show you ads on Roblox. To the extent these practices involve the processing of Personal Information to display personalized ads, the legal basis for the processing is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”). To the extent these practices involve the processing of Personal Information to display non-personalized ads, the legal basis for processing is Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Qualifications & exceptions

• Basis depends on whether the ads are personalized.

Not stated here

• Which partners are involved is not stated.

Use & Processing · Company practice

EEA/UK/Swiss list: advertising measurement rests on legitimate interest

The list says Roblox will process information collected from or about you to measure and improve advertising effectiveness, on the basis Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest"). The passage states "will process", with no consent step for this purpose.

Supporting quotations

Roblox will process information collected from or about you to measure and improve advertising effectiveness. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Qualifications & exceptions

• Basis stated is legitimate interest.

Not stated here

• Whether this list offers a way to object to measurement is not stated in this passage.

Use & Processing · Company practice

EEA/UK/Swiss list: marketing Roblox on other sites and apps rests on consent

The list says that to market its services on other sites and apps, for example via social media platforms, to bring new users and maintain and increase its user base, Roblox may process Personal Information. To the extent this involves processing Personal Information, the stated legal basis is Article 6 sec. 1 sent. 1 lit. a GDPR ("consent").

Supporting quotations

To market our services on other sites and apps, for example, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process Personal Information. To the extent these practices involve the processing of Personal Information, the legal basis for the processing is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”).

Qualifications & exceptions

• Applies to marketing Roblox on other sites and apps.
• Basis stated is consent.

Not stated here

• The passage does not say what Personal Information is processed or who receives it.

Charges & Financial Obligations · Company practice

EEA/UK/Swiss list: ad publishers' data rests on contract, legitimate interest and legal obligation, including tax law

The list says that if you choose to publish ads on Roblox, it collects additional information from you (such as name, email, address, financial information and business information) to create an ad account, onboard you to the ad program and send invoices or payment information, on the basis Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). It may also retain transaction details and purchase and payment history on the basis of its legitimate interest in resolving later disputes and inquiries (lit. f). It also collects and retains information to comply with legal obligations including tax laws, on the basis Article 6 sec. 1 sent. 1 lit. c GDPR ("legal obligation").

Supporting quotations

If you choose to publish ads on Roblox, we collect additional information from you (such as name, email, address, financial information, business information, etc.) in order to create an ad account, onboard you to the relevant ad program, and send you invoices or information related to payment.

We may also retain transaction details and purchase and payment history. The legal basis for processing these Personal Information is our legitimate interest in being able to resolve subsequent disputes and inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

We also collect and retain your information to comply with our legal obligations, including our obligations under tax laws. The basis for processing this Personal Information is Article 6 sec. 1 sent. 1 lit. c GDPR (“legal obligation”).

Qualifications & exceptions

• Applies if you choose to publish ads on Roblox.
• Three bases: contract, legitimate interest, legal obligation.

Not stated here

• How long transaction details and payment history are retained is not stated.

Cross-references

• contrast (model-proposed): EEA/UK/Swiss list: account, improvement and safety purposes rest on legitimate interest; compliance bases listed — The same "legal obligation" label is cited with lit. c in the ad publisher entry and with lit. b in the other purposes entry. The source is quoted as written and not corrected.

Charges & Financial Obligations · Company practice

EEA/UK/Swiss list: Developer Exchange tax forms are processed on legitimate interest in meeting US legal requirements

The list says information required to take part in the Roblox Developer Exchange Program, like the IRS W-9 form (US taxpayers) or W-8 form (non-US taxpayers), is processed on the basis Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest") with regard to US law requirements. It says it is Roblox's legitimate interest to comply with the legal requirements, especially US anti-money laundering laws.

Supporting quotations

If you’re a developer or creator

Information required for participating in our Roblox Developer Exchange Program, like the IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers). The legal basis for this processing is Article 6 sec.1 sent. 1 lit. f GDPR (“legitimate interest”) with regard to U.S. law requirements. It is our legitimate interest to comply with the legal requirements, especially with regard to U.S. anti-money laundering laws.

Qualifications & exceptions

• Applies to developers and creators taking part in the Developer Exchange Program.

Not stated here

• The US laws are named only in general terms (anti-money laundering laws) and are not supplied here.

Legal Rights & Agreement Rules · Company practice

EEA/UK/Swiss list: account, improvement and safety purposes rest on legitimate interest; compliance bases listed

The list says Roblox collects and processes Personal Information for other legitimate purposes including: letting you manage your account and services, making things better for you, and protecting you by keeping the platform safe and secure, on the basis Article 6 sec.1 sent. 1 lit. f GDPR ("legitimate interest"). It says it also uses data to comply with law and its policies, on the basis of Article 6 sec.1 sent. 1 lit. b GDPR ("performance of a contract") and, as the source words it, "Article 6 sec.1 sent. 1 lit. b GDPR (“legal obligation”)". The source gives lit. b for both labels, whereas the ad publisher entry gives lit. c for "legal obligation"; the policy does not explain this and it is not corrected here.

Supporting quotations

Other purposes for collecting your information

We collect and process Personal Information for other legitimate purposes including the following. We collect and process data to let you manage your account and our services, to make things better for you, and to protect you by keeping our platform safe and secure. The legal basis for this processing is Article 6 sec.1 sent. 1 lit. f GDPR (“legitimate interest”).

We also use data to comply with law and our policies. The legal basis for this processing is Article 6 sec.1 sent. 1 lit. b GDPR (“performance of a contract”) and Article 6 sec.1 sent. 1 lit. b GDPR (“legal obligation”).

Qualifications & exceptions

• The legitimate interest basis covers account management, improvement and safety; the contract and legal obligation bases cover compliance.
• The "legal obligation" label appears with lit. b in this passage and with lit. c in the ad publisher entry.

Not stated here

• Whether "lit. b" for "legal obligation" is intended is not stated; the source wording is quoted unchanged.

Cross-references

• contrast (model-proposed): EEA/UK/Swiss list: ad publishers' data rests on contract, legitimate interest and legal obligation, including tax law — The same "legal obligation" label is cited with lit. c in the ad publisher entry and with lit. b in the other purposes entry. The source is quoted as written and not corrected.

Use & Processing · User right or choice

EEA/UK/Swiss list: necessary cookies cannot be turned off; optional cookies need prior consent

The list says Roblox uses cookies, some necessary for the basic functioning of the website, which therefore cannot be deactivated. The stated basis is Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and Art. 6 sec. 1 sent. 1 lit. f ("legitimate interest"), because of a legitimate interest to guarantee the Services' stability and security. It says optional cookies will be used only if you have previously consented. With an EEA IP address a cookie banner asks for your consent, you can manage your choice via "manage cookie preferences", and your choices are saved in a cookie with a limited effective period of one year, on the basis Article 6 sec. 1 sent. 1 lit. a ("consent"). You can also manage cookies using browser settings, and it refers to Section 3 above for more on cookies and similar technologies.

Supporting quotations

Cookies and similar technologies

We use cookies. Some of these cookies are necessary for the basic functioning of the website and therefore cannot be deactivated.

We will use optional cookies only if you have previously consented to such use. When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent.

This cookie has a limited effective period of one year.

For further information on cookies and similar technologies see Section 3 above.

Qualifications & exceptions

• Necessary cookies cannot be deactivated.
• Optional cookies are used only with prior consent.
• The consent banner appears with an EEA IP address.

Not stated here

• Which cookies are "necessary" and which are "optional" is not listed.

Data Access & Collection · Company practice

EEA/UK/Swiss list: job application data is processed to respond to the application; career spaces may be recorded

The list says information relating to a job application, like your name, email address, employment details, CV, resume or other employment history details, is processed to process and respond to the application. If you engage with Roblox in an immersive space for prospective employees, such as the Roblox Career Center, the space may be recorded to provide the experience. The stated legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("necessary for entering into an employment contract with us").

Supporting quotations

On our corporate websites or in job applications

Information relating to a job application made by you, like your name, email address, employment details, CV, resume or other details of your employment history sent by you. We will process this information to process and respond to your job application.

such a space may be recorded in order to provide the experience

Qualifications & exceptions

• Applies to people who apply for jobs.
• Recording applies to immersive spaces for prospective employees and is stated "may".

Not stated here

• How long job application information is kept is not stated in this passage.

Use & Processing · Company commitment

EEA/UK/Swiss list: no automated decision making with legal or similarly significant effects

The list says that Roblox does not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

Supporting quotations

Automated Decision-Making

Please note that we do not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

Qualifications & exceptions

• Limited to automated decision making that produces legal effects or similarly significantly affects you.

Not stated here

• The passage does not say whether other automated processing, such as content filtering, falls inside or outside this statement.

Account & Service Control · Company commitment

EEA/UK/Swiss list: under-13 accounts start with privacy-protective settings, without personalized ads and some alerts

In the children's section of the list, the policy says that when users under 13 (called a "child" for this section) register for the Service, their account is automatically set to privacy-protective settings by default. These users will not have access to certain features, including personalized advertising and certain types of notification alerts.

Supporting quotations

Personal Information of Children and Parental Consent

when users under the age of 13 (for the purposes of this section, a “child”) register for the Service, their account is automatically set to privacy-protective settings by default. This means that these users will not have access to certain features, including personalized advertising, and certain types of notification alerts.

“Children” or “Child” means any user under the age of 13

Qualifications & exceptions

• Applies to users under 13 at registration.
• Which features are unavailable is limited to "certain features", including personalized advertising and certain notification alerts.

Not stated here

• The full list of unavailable features is not given.

Cross-references

• referred to by (model-proposed): Accounts under 13 start with stronger privacy settings, and ads are not personalized until the user is 18 — The EEA/UK/Swiss list repeats the under-13 privacy-protective defaults described in the under-13 part.

Data Access & Collection · Company practice

EEA/UK/Swiss list: child account data gives access and contacts the parent; birth date sets features

The list says that when a child creates an account Roblox may process a username, password, birthdate and gender (gender is optional), and that separately users may optionally provide a parent email address. It processes this information to give the user access to the Service and to communicate with the parent about the child's account, for example by emailing a notification and an invitation for the parent to review the account and update settings. It may use the birthdate to decide which features the child should have access to and to determine when the child turns 13 and can be given broader access. The stated basis is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract").

Supporting quotations

When a child creates an account on Roblox, we may process a username, password, birthdate, and gender (gender is optional). Separate from account creation, users may optionally provide a parent email address.

We process this information to give the user access to the Service and to communicate with the parent about the child’s account (if a parent email was provided).

We may use the birthdate the child provides when signing up for the Service to determine which features on Roblox the child should have access to and to determine when the child will turn 13 years old and can be given broader access to features on our Service. This processing activity is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

Qualifications & exceptions

• Applies when a child under 13 creates an account.
• Gender and the parent email address are optional.
• Parent communication applies only if a parent email was provided.

Not stated here

• Which features are tied to the birthdate is not listed.

Sharing & Disclosure · Company commitment

EEA/UK/Swiss list: child account information is used only for stated purposes; parental consent if the law requires

The list says that in general Roblox will not use or share account information (including Personal Information) from a child's account except for the permissible purposes stated in the Privacy Policy and, if required by law, only with the prior verifiable consent of a parent or legal guardian (Article 6 sec. 1 sent. 1 lit. a and Article 8 sec. 1 GDPR).

Supporting quotations

In general, we will not use or share account information (including Personal Information) from a child’s account except for the permissible purposes stated in this Privacy Policy, and, if required by law, only with the prior verifiable consent of a parent or legal guardian (Article 6 sec. 1 sent. 1 lit. a and Article 8 sec. 1 GDPR).

Qualifications & exceptions

• The commitment is "in general".
• Parental consent is required only "if required by law".

Not stated here

• In which cases the law requires verifiable parental consent is not stated.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: service providers receive information under Article 28 agreements for assigned tasks only

The list says Roblox may share users' information, including Personal Information like billing information or usernames, with third-party agents, contractors or service providers hired to perform services on its behalf, who may operate or support certain functions of the Service. It gives an illustrative list of functions and providers: account integrity and security (for example Persona), analytics (Google LLC), user acquisition (AppsFlyer), community filtering and moderation, customer support, surveys and promotions (Reach3), billing services and payment gateway providers (Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla), and hosting and content delivery network services (AWS, Equinix, CenturyLink, YouTube, Vimeo). The stated legal basis is Article 28 of GDPR in conjunction with the data processing agreements with the agents. The agents may use the information only for the specific tasks they were hired for, consistent with the Privacy Policy, and Roblox says it takes steps so that all service providers with access to Personal Information are capable of protecting it.

Supporting quotations

Data Sharing

Roblox may share users’ information, including Personal Information like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Roblox’s behalf.

Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions:

Account Integrity and Security (e.g., Persona);

Analytics services (e.g., Google LLC);

User Acquisition services (e.g., AppsFlyer);

Community filtering and moderation services;

Customer support services;

Surveys and promotions (e.g., Reach3);

Billing services and payment gateway providers (e.g., Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla); and

Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink, YouTube, Vimeo).

The legal basis for this data transfer and processing activity is Article 28 of GDPR in conjunction with the data processing agreements we concluded with respective third-party agents. These agents and contractors are only allowed to use the information shared with them only for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes.

Qualifications & exceptions

• The list of providers is "illustrative".
• Providers may use the information only for the tasks they were hired to do.

Not stated here

• Which providers actually receive which information is not stated.
• The data processing agreements are not supplied.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: creators see usernames, user ID, game metrics, UGC details and region; IP address is not shared

The list says creators of the experiences you use or content you interact with have access to your username, display name, user ID, game metrics, UGC transaction details and your regional location (based on your IP address), and that Roblox does not share your IP address with creators. Regional location is given to creators to determine their player base and ensure their experiences meet the legal requirements of the country you live in. The stated bases are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"), lit. c ("compliance with legal obligation") in compliance with the respective EEA or Member State law, and lit. f ("legitimate interest"). It says it is the creators' legitimate interest to comply with non-EEA legal obligations.

Supporting quotations

the creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators.

We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in.

It is the creators’ legitimate interest to comply with non-EEA legal obligations.

Qualifications & exceptions

• Applies to creators of the experiences you use or content you interact with.
• The IP address itself is not shared.

Not stated here

• What creators may do with this information beyond the stated purposes is not addressed.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: disclosure to advertising partners rests on consent; measurement covers contact and device IDs

The list says that in accordance with applicable laws Roblox may disclose information collected from or about you to advertisers and/or advertising measurement companies to select advertisements for you or to measure and improve advertising effectiveness. The stated legal basis for disclosing information to third-party advertising partners is Article 6 sec. 1 sent. 1 lit. a ("consent"). Data disclosed for advertising measurement includes contact identifiers and device identifiers, on the basis of legitimate interest (lit. f). The source writes the measurement basis as "Article 6 sec. sent. 1 lit. f", omitting the paragraph number, which is quoted as given.

Supporting quotations

In accordance with applicable laws, Roblox may disclose information collected from or about you with advertisers and/or advertising measurement companies to select advertisements for you, or measure and improve advertising effectiveness. The legal basis for disclosing information to third party advertising partners is Article 6 sec. 1 sent. 1 lit. a(“consent”).

Data disclosed for advertising measurement purposes includes contact identifiers and device identifiers. The legal basis for this processing activity is Article 6 sec. sent. 1 lit. f (“legitimate interest”).

Qualifications & exceptions

• Disclosure for advertising partners rests on consent; measurement disclosure rests on legitimate interest.
• The measurement data list says "includes".

Not stated here

• The citation for the measurement basis omits a paragraph number in the source and is not corrected here.

Charges & Financial Obligations · Company practice

EEA/UK/Swiss list: Roblox and a Commerce Provider exchange purchase information on a contract basis

The list says that if you directly interact with a Commerce Provider to purchase a Commerce Product on Roblox, Roblox and the provider may need to exchange information about the purchase to fulfill the transaction, including a transaction identifier that lets each party confirm certain information such as whether a purchase has been completed. The stated legal basis for data sharing required to facilitate a purchase through a fulfillment partner is Article 6 sec. 1 sent. 1 lit. b ("performance of a contract").

Supporting quotations

If you directly interact with a Commerce Provider to purchase a Commerce Product(s) on Roblox, Roblox and the Commerce Provider may need to exchange information about your purchase in order to fulfill the transaction.

The legal basis for data sharing required to facilitate a purchase you make through a fulfillment partner is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”).

Qualifications & exceptions

• Applies when you interact directly with a Commerce Provider to buy a Commerce Product.

Not stated here

• "Commerce Provider" and "Commerce Product" are not defined in this passage.
• The passage does not repeat the general statement that information you give the provider is collected by the provider.

Sharing & Disclosure · Permission or license

EEA/UK/Swiss list: Roblox may disclose information and communication content for legal process and agency requests

The list says Roblox may disclose Personal Information about you, including the content of your communications on the Service, to comply with legal process such as court orders and subpoenas, for example where consistent with its obligations under the Digital Services Act, Article 18 and information notices under the UK Online Safety Act. It may also disclose Personal Information, including content, in response to a request from law enforcement agencies, regulators or other public agencies (including schools or children services) if it believes there is a risk to user safety or security, for legal reasons, or to prevent a crime, in accordance with Section 4 of the policy. The stated bases are Article 6 sec. 1 sent. 1 lit. c ("compliance with legal obligation") in compliance with the respective EEA or Member State law, and lit. f ("legitimate interest"); it says it is Roblox's legitimate interest to comply with the legal requirements of U.S. law and that it has a legitimate interest in these purposes.

Supporting quotations

Legal disclosure

We may disclose Personal Information about you, including the content of your communications on the Service, to comply with legal process, including court orders and subpoenas, served on our Service

In addition, we also may disclose Personal Information about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), if we believe that there is a risk to user safety or security, for legal reasons, or to prevent a crime, in accordance with Section 4 of the Roblox Privacy and Cookie Policy.

It is our legitimate interest to comply with the legal requirements of U.S. law.

Qualifications & exceptions

• Agency requests lead to disclosure if Roblox believes there is a risk to user safety or security, for legal reasons, or to prevent a crime.
• Legal bases include a legitimate interest in complying with U.S. law.

Not stated here

• What the Digital Services Act and UK Online Safety Act require is not supplied here.
• "Section 4" is referred to by number; the source does not print section numbers.

Sharing & Disclosure · Company practice

EEA/UK/Swiss list: information is stored on US servers; safeguards include Standard Contractual Clauses

The list says Roblox is based in the U.S. and that Personal Information it collects is sent to and stored on secure servers in the United States, which it calls necessary to process the information. Some of its agents and third-party service providers are outside the European Economic Area, for example in the United States. It says the data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence. Wherever it transfers Personal Information it says it will take reasonable steps so that privacy rights continue to be protected, for example by concluding the EU Standard Contractual Clauses with third parties.

Supporting quotations

Storage and international transfer of your Personal Information

Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America.

Some of our agents and third-party service providers are located outside the European Economic Area, e.g. the United States.

Wherever we transfer your Personal Information, we will take reasonable steps so that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.

Qualifications & exceptions

• Storage is on servers in the United States.
• The Standard Contractual Clauses are given as an example ("e.g.") of reasonable steps.

Not stated here

• The text of the Standard Contractual Clauses is linked but not supplied here.
• Which safeguards apply for UK and Swiss transfers is not stated.

Use & Processing · User right or choice

EEA/UK/Swiss list: EEA users may request access, rectification, removal or restriction, and withdraw consent

The list says users based in the EEA may be entitled to exercise some or all of the following rights: to request information on whether Personal Information is retained and access to or copies of it, including the purposes of the processing, the categories of Personal Information, the recipients and potential retention periods; to request rectification, removal or restriction, for example because the information is incomplete or inaccurate, no longer needed for its purpose, or the consent behind the processing was withdrawn; and to refuse to provide, and withdraw at any time, consent to processing, without effect on processing already done before withdrawal.

Supporting quotations

Your rights as a Data Subject

If you are a user based in the European Economic Area, you may be entitled to exercise some or all of the following rights:

Request (i) information whether your Personal Information is retained and (ii) access to or duplicates of your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the data recipients as well as potential retention periods;

Request rectification, removal or restriction of your Personal Information, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;

Refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time;

Qualifications & exceptions

• The rights apply to users based in the EEA and are described as rights the user "may be entitled" to, "some or all" of them.
• Withdrawing consent does not affect processing done before withdrawal.

Not stated here

• Whether UK and Swiss users have these rights is not stated in this passage.

Use & Processing · User right or choice

EEA/UK/Swiss list: EEA users may object to processing and direct marketing and request portable data

The list says EEA users may also object, on grounds relating to their particular situation, to processing based on Roblox's or a third party's legitimate interests or on a task carried out in the public interest; in that case they should give information about their situation, and after assessing it Roblox says it will either stop processing or present its compelling legitimate grounds for continuing. Users may object to the use of Personal Information for direct marketing at any time. They may also request to receive Personal Information they provided in a structured, commonly used and machine-readable format and to transmit it to another controller without hindrance, and, where technically feasible, to have it transmitted directly from Roblox to another controller.

Supporting quotations

Object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest.

After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing;

Object to the use of your Personal Information for direct marketing at any time;

Request (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side. Where technically feasible you shall have the right to have the Personal Information transmitted directly from us to another controller.

Qualifications & exceptions

• Objection to legitimate-interest processing requires the user's particular situation; Roblox may continue if it presents compelling legitimate grounds.
• Direct marketing objection is available at any time.
• Direct transmission to another controller is where technically feasible.

Not stated here

• What counts as a "compelling" ground is not defined.

Legal Rights & Agreement Rules · User right or choice

EEA/UK/Swiss list: rights requests go to the Section 1 contacts; you may take legal action or complain to regulators

The list says you may exercise the rights above, ask questions or make complaints about Roblox's data processing by contacting Roblox under the contact details set out above in Sec. 1. It adds that you may take legal action in relation to any potential breach of your rights regarding the processing of your Personal Information, and lodge complaints with the competent data protection regulators.

Supporting quotations

You may (i) exercise the rights referred to above, (ii) pose any questions, or (iii) make any complaints regarding our data processing by contacting us under the contact details set out above in Sec. 1.

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators.

Qualifications & exceptions

• Contact is through the details in Section 1 of the policy.

Not stated here

• "Sec. 1" is referred to by number; the source does not print section numbers.

Legal Rights & Agreement Rules · Context

Brazil list: Roblox lists categories of Personal Information processed for people living in Brazil

For people living in Brazil, the policy says that in the course of visiting its websites and apps or using its services and products Roblox may process the Personal Information listed under the following entries. The entries follow.

Supporting quotations

If you live in Brazil

Categories of Personal Information and Data Processing Purposes

In the course of visiting our websites and apps, and/or using our services and products, we may process the following Personal Information:

Qualifications & exceptions

• Applies to people living in Brazil.

Not stated here

• The categories are in the entries that follow.

Data Access & Collection · Company practice

Brazil list: username, password and verification email are processed to set up and secure your account

The list for Brazil says Roblox processes a username and password to create your account, and email addresses and other information you provided for added verification and/or to enable certain features. It states that Roblox has a legitimate interest in providing a safe and secure Service, especially to protect children. Unlike the EEA list, this passage does not cite Article 6 bases.

Supporting quotations

Setting up a Roblox account

Username and password to create your account.

Email addresses and other information you provided us with for added verification and/or to enable certain features. Roblox has a legitimate interest in providing a safe and secure Service, especially to protect children.

Qualifications & exceptions

• Applies to people living in Brazil.

Not stated here

• This passage names no legal basis other than Roblox's stated legitimate interest.

Data Access & Collection · Company practice

Brazil list: phone numbers are used for security and login; friend recommendations need explicit and informed consent

The list for Brazil says that if you choose to provide a phone number, Roblox uses it for security and account access, to log in via mobile and recover a lost or forgotten password. You authorize your wireless carrier to use or disclose information about your account and device to Roblox or its service provider for the duration of your business relationship, solely to help identify you or your device and to prevent fraud. Roblox states a legitimate interest in enabling mobile use, ensuring security and preventing fraud. With your explicit and informed consent it may use your phone number to recommend you as a friend to others on Roblox.

Supporting quotations

If you choose to provide a phone number, we will use the phone number for security and account access purposes, which will allow you to log in via mobile and recover a lost or forgotten password.

We have a legitimate interest in enabling you to use our Services via your mobile device, ensuring security, and preventing fraud.

Additionally, with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Roblox.

Qualifications & exceptions

• Providing a phone number is a choice.
• Friend recommendations require explicit and informed consent.
• Carrier authorization is limited to identifying you or your device and preventing fraud.

Not stated here

• Whether the Discoverability feature is unavailable in some locations is not stated in this passage.

Charges & Financial Obligations · Company practice

Brazil list: billing and payment data is collected for purchases; saved card data stays with the third-party partner

The list for Brazil says Roblox collects billing and payment information when you participate in Developer Exchange or purchase Robux or premium subscriptions for yourself or another user, including name, billing address, credit card or other payment information. If you save information such as a credit card number with a third-party payment provider, it is stored with the partner and not by Roblox. Roblox may also collect billing addresses and retain transaction details and purchase and payment history. If you buy Robux for another user, it collects contact information such as email or phone number to communicate about the transaction.

Supporting quotations

Purchases on Roblox

Billing and payment information, when you participate in Developer Exchange or purchase Robux or premium subscriptions on behalf of yourself or another user, including your name, billing address, credit card or other payment information and billing information.

You may choose to save information such as your credit card number through a third-party payment provider; in such cases the information is not stored by Roblox; it is stored with the third-party partner.

We may also collect billing addresses and retain transaction details and purchase and payment history.

Qualifications & exceptions

• Applies to people living in Brazil.
• Saved card information is stored with the third-party partner, not Roblox.

Not stated here

• How long transaction details and payment history are kept is not stated in this passage.

Use & Processing · Company practice

Brazil list: posts are monitored and filtered; other users can read and use what you post

The list for Brazil says Roblox processes comments or messages you post via public chats, forums, group walls and personal posts to monitor, filter and moderate them so it can remove profanity, Personal Information and other inappropriate conversations, and may use pre-filtered comments and messages for other purposes such as training and improving its filter technology. It warns that Personal Information you submit in forums and similar means is available to anyone with access, including other users, and could be read, collected or used by other users, including to send unsolicited messages.

Supporting quotations

Posting content

We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, Personal Information, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology.

Please note that any Personal Information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The Personal Information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.

Qualifications & exceptions

• Applies to people living in Brazil.
• Training and improving filter technology uses pre-filtered comments and messages.

Not stated here

• This passage names no legal basis.

Data Access & Collection · Company practice

Brazil list: customer service contact details are processed to respond and support you

The list for Brazil says Roblox processes information about contacting customer service, for example when you report a problem or submit questions, concerns or comments: your email address, your name and information about your inquiry, in order to respond, fulfill requests or provide other customer support.

Supporting quotations

Asking questions or getting technical support

We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support.

Qualifications & exceptions

• Applies to people living in Brazil.

Not stated here

• This passage does not say how long the records are kept.

Linking & Identification · Company practice

Brazil list: third-party plug-ins and social links can exchange information with Roblox and post to your profiles there

The list for Brazil says information relating to your use of or interaction with third-party plug-ins, for example social plugins from Google, Facebook or Twitter, and social media links you add to your account, are covered. When you use these features, certain information from your social media accounts may be accessed by or shared with Roblox, and likewise certain information about your use of Roblox may be posted to your profile on those platforms. If you use your Roblox credentials to sign in to a third-party website or service and later delete your Roblox account, you may lose access to that website or service.

Supporting quotations

Using Roblox Features

Social media links you add to your account.Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter.

When you use these features, certain information from your social media accounts may be accessed by or shared with Roblox, and likewise, certain information about your use of Roblox may be posted to your profile on those platforms.

If you use your Roblox credentials to sign in to a third-party website or service, and later delete your Roblox account, you may lose access to such third-party website or service.

Qualifications & exceptions

• Applies to people living in Brazil.
• Information may flow both ways: to Roblox and onto your profile on those platforms.
• Losing third-party access is stated as "may".

Not stated here

• Which information about your use of Roblox may be posted to those platforms is not stated.

Use & Processing · Company commitment

Brazil list: no training on private server voice chat of Brazil users; other voice training only with consent

The list for Brazil says that when you use audio features Roblox may collect, process and store your audio recording to enable voice services and make Roblox safer. It says it will not engage in training or product improvement with private server voice chat recordings of Brazil users, and that with your consent it will use voice recordings to inform training and product improvement.

Supporting quotations

When you use audio features from Roblox, we may collect, process, and store your audio recording to enable voice services and make Roblox safer.

We will not engage in training or product improvement with private server voice chat recordings of Brazil users. With your consent, we will use voice recordings to inform training and product improvement.

Qualifications & exceptions

• The private server commitment is stated for Brazil users.
• Training and product improvement from voice recordings requires consent.

Not stated here

• Whether consent can be withdrawn is not stated in this passage.

Cross-references

• contrast (model-proposed): Voice and audio you use is monitored, collected, used and stored for voice chat, safety, training and screen recordings — The Brazil list makes a similar commitment not to train on private server voice chat recordings of Brazil users, with training from voice recordings using consent, whereas the general audio passage lists training and product improvement in accordance with applicable law.

Data Access & Collection · User right or choice

Brazil list: geolocation is collected for location services for users 13 and older, using a device or browser identifier

The list for Brazil says that when you request or agree to location-based services (users 13 and older), Roblox may collect and track geolocation information so it can offer services that depend on knowing where you are, with examples of personalizing content or personalized advertising for users 18 and older. It collects this using an identifier on your device or browser so it can recognize you when you return. To stop collection you can update device settings, stop using the service, or uninstall the mobile apps.

Supporting quotations

When you request or agree to location-based services (users 13 years old and older), we may collect and track geolocation information so that we can offer services that depend on us knowing where you are.

To stop us collecting your location information, you can update your device settings, stop using the service, or uninstall our mobile apps.

Qualifications & exceptions

• Applies when you request or agree to location-based services; users 13 and older.

Not stated here

• Which services depend on location is not listed.

Data Access & Collection · Company commitment

Brazil list: VR movement information is collected to replicate your movement and is not stored

The list for Brazil says that if you join experiences on a VR platform, Roblox collects your physical movement information in order to replicate your movement in the experience. It says the information is only used to provide the Service and is not stored.

Supporting quotations

If you join our experiences on a VR platform, we will collect your physical movement information in order to replicate your movement in the experience. This information is only used to provide the Service and is not stored.

Qualifications & exceptions

• Applies when you join experiences on a VR platform.

Not stated here

• Whether the VR platform provider keeps this information is not addressed.

Sharing & Disclosure · Company practice

Brazil list: Creator Event data goes to the third-party platform hosting the event

The list for Brazil says that if you join a virtual event hosted by a Creator, data such as your username, email and Roblox user ID may be shared with the third-party platform that hosts events, to allow you to log in. Your activity during a Creator Event is subject to that platform's privacy policy as well as the Roblox Community Standards.

Supporting quotations

If you join a virtual event hosted by a Creator, data such as your username, email, and Roblox user ID may be shared with the third-party platform that hosts events. Such data is used to allow you to log in to the experience.

Your activity during a Creator Event is subject to the third party platform’s privacy policy as well as the Roblox Community Standards

Qualifications & exceptions

• The data listed is introduced by "such as".

Not stated here

• The third-party platform's privacy policy and the Roblox Community Standards are not supplied here.

Data Access & Collection · Company practice

Brazil list: camera and upload content is collected, processed and stored for the feature's purpose

The list for Brazil says that for features that require your camera or let you upload content containing your Personal Information, including photos or videos, Roblox will collect, process and store that content to accomplish the purpose of the feature. It refers to a Roblox Facial Animation Privacy Notice and a Roblox Facial Media Capture Privacy Notice for more.

Supporting quotations

If you decide to use these features and upload content, we will collect, process, and store that content to accomplish the purpose of the feature.

Qualifications & exceptions

• Applies to people living in Brazil.

Not stated here

• The two privacy notices are not supplied here.
• This passage does not state a storage time limit.

Data Access & Collection · Company commitment

Brazil list: other features for users who are not children will show what is collected at the time of collection

The list for Brazil says information required for other features or activities, which may be available to users other than children, may be offered from time to time, and you may be able to submit or upload Personal Information with them. It says the data collected and its intended uses will be evident at the time of data collection.

Supporting quotations

We may offer other features or activities on our Services from time to time, and you may be able to submit or upload Personal Information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection.

Qualifications & exceptions

• Applies to features or activities available to users other than children.

Not stated here

• The features and the data they collect are not listed.

Data Access & Collection · Company practice

Brazil list: Contact Importer shares your contacts' names and phone numbers with Roblox

The list for Brazil says that if you opt in to the Contact Importer feature you consent to sharing with Roblox the first and last names and phone numbers of the contacts in your address book on your mobile phone, either at registration or otherwise, to help you connect with friends.

Supporting quotations

If you opt-in to the Contact Importer feature, you consent to sharing with Roblox the first and last names and phone numbers of your contacts in your address book on your mobile phone, either at the time you register for our Service or otherwise. We do so to help you connect with your friends on our Service.

Qualifications & exceptions

• Opt-in.

Not stated here

• This passage does not repeat the age limit or retention statement from the general Contact Importer description.

Use & Processing · Company practice

Brazil list: interaction data, game state, search history and UGC details are collected and linked to your account

The list for Brazil says that to improve your experience and support safety, Roblox collects information about how you interact with the Services and connects it with your account. Examples: a user's game state to detect Terms violations; behavior when you interact with your device for security and safety; information from your search history to give similar recommendations; and sharing your username and transaction details with the UGC creator or subsequent owners if you acquire a limited item or otherwise transact in UGC.

Supporting quotations

To improve your experience and support our safety efforts, we collect information about how you interact with the Services and we connect this information with your account.

collect information from your search history to give you similar recommendations

share information like your username and transaction details to the UGC creator or subsequent owners, if you acquire a limited item if you purchase, share, trade, or otherwise engage in a transaction involving UGC.

Qualifications & exceptions

• The items are introduced by "for example", so they are not stated to be complete.

Not stated here

• This list names "search history" as a recommendation input; the general description names the games you play.

Cross-references

• contrast (model-proposed): Roblox collects information about how you interact with the Services and links it to your account — The Brazil list names search history for recommendations where the general passage names the games you are playing.

Data Access & Collection · Company practice

Brazil list: voluntary research and surveys may collect interests, habits and lifestyle information

The list for Brazil says that when you respond to or take part in voluntary research, surveys or studies, these may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences, and may ask for Personal Information.

Supporting quotations

Competitions, promotions, and research

When you respond to or participate in voluntary research or surveys or studies. These surveys may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for Personal Information.

Qualifications & exceptions

• Applies to voluntary research, surveys or studies.

Not stated here

• This passage names no legal basis.

Data Access & Collection · Company practice

Brazil list: contest and promotion contact details are processed for prize fulfillment

The list for Brazil says that for contests, competitions, sweepstakes, giveaways, prize draws or other promotions that Roblox runs or sponsors, it may process certain contact information (such as name, email address and/or phone number) for prize fulfillment, as well as other information or content needed for the specific promotion.

Supporting quotations

We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion.

Qualifications & exceptions

• Contact details are listed "such as".

Not stated here

• The passage does not mention gift card providers or publishing winners, which the general description covers.

Use & Processing · Company practice

Brazil list: Personal Information is processed to display ads; no personalized ads for under-18s

The list for Brazil says Roblox processes Personal Information to display ads on Roblox, using information it collects and receives from partners to decide which ads to show. It says that, depending on where you live, Roblox also may work with partners to directly show you ads. It says it does not show personalized ads to users under 18.

Supporting quotations

Advertising

We process Personal Information to display ads on Roblox. We use information we collect and receive from partners to decide which ads to show you on Roblox. Depending on where you live, Roblox also may work with partners to directly show you ads on Roblox.

We do not show personalized ads to users under the age of 18 on Roblox.

Qualifications & exceptions

• Partner-shown ads depend on where you live.
• Personalized ads are not shown to users under 18.

Not stated here

• Which places have partner-shown ads is not stated.

Use & Processing · Company practice

Brazil list: information is processed to measure advertising and to market Roblox on other sites and apps

The list for Brazil says Roblox will process information collected from or about you to measure and improve advertising effectiveness. It also says that to market its services on other sites and apps, for example via social media platforms, to bring new users and maintain and increase its user base, it may process Personal Information.

Supporting quotations

Roblox will process information collected from or about you to measure and improve advertising effectiveness.

To market our services on other sites and apps, for example, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process Personal Information.

Qualifications & exceptions

• Marketing on other sites and apps is "may process".

Not stated here

• These passages name no legal basis or choice mechanism.

Charges & Financial Obligations · Company practice

Brazil list: creating an Ad Account collects contact and business information; transaction history may be kept

The list for Brazil says that when you choose to create an Ad Account, Roblox may collect additional information (such as name, email, address and business information) in order to create the account, and may also retain transaction details and purchase and payment history.

Supporting quotations

When you choose to create an Ad Account, we may collect additional information for your account (such as name, email, address, business information, etc.) in order to create an account. We may also retain transaction details and purchase and payment history.

Qualifications & exceptions

• Applies when you choose to create an Ad Account.
• The information listed is introduced by "such as".

Not stated here

• This passage does not mention tax or financial information, which the general description lists for publishing ads.

Charges & Financial Obligations · Company practice

Brazil list: Developer Exchange requires a W-9 or W-8 form; Roblox cites US legal requirements

The list for Brazil says information required to take part in the Roblox Developer Exchange Program, like the IRS W-9 form (US taxpayers) or W-8 form (non-US taxpayers), is collected, and states that it is Roblox's legitimate interest to comply with the legal requirements, especially US anti-money laundering laws.

Supporting quotations

If you’re a developer or creator

Information required for participating in our Roblox Developer Exchange Program, like the IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers). It is our legitimate interest to comply with the legal requirements, especially with regard to U.S. anti-money laundering laws.

Qualifications & exceptions

• Applies to developers and creators taking part in the Developer Exchange Program.

Not stated here

• The US laws are named only in general terms and are not supplied here.

Data Access & Collection · Company practice

Brazil list: login information includes IP address, device and browser details, MAC addresses and user ID

The list for Brazil says login information may include your IP address, device type, username, password, date and time of your visit, browser version, operating system information including language settings, MAC addresses and User ID. Roblox says it processes this information to provide the Service, and that it is in its legitimate interest to guarantee the Services' stability and security.

Supporting quotations

Other purposes for collecting your information

Login information, which may include your IP address, device type, username, password, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with our Service. It is in our legitimate interest to guarantee the Services’ stability and security.

Qualifications & exceptions

• The items are introduced by "may include".

Not stated here

• This passage does not state how long login information is kept.

Data Access & Collection · Company practice

Brazil list: account information, including login, location and user content, is processed to provide the Services

The list for Brazil says account information, for example your name, username, login and password details, regional location information, user-generated content, contact details you choose to provide and other Personal Information used for participating in the Service, is processed to provide the Services to you.

Supporting quotations

Account information, e.g. information such as your name, username, login and password details, regional location information, user-generated content, contact details that you choose to provide to us, and other Personal Information that are used for participating in the Service we are offering. We process this information to provide our Services to you.

Qualifications & exceptions

• The items are introduced by "e.g." and "such as".
• Contact details are those you choose to provide.

Not stated here

• The passage does not say whether account information is used for other purposes.

Use & Processing · User right or choice

Brazil list: necessary cookies cannot be turned off; optional cookies need prior consent; consent choice lasts one year

The list for Brazil says Roblox uses cookies, some necessary for the basic functioning of the website, which cannot be deactivated. It will use optional cookies only if you have previously consented, you can manage your choice via "manage cookie preferences" in the cookie banner, and the choice is saved in a cookie with a limited effective period of one year. You can also manage cookies with browser settings, and it refers to Section 3 above for more on cookies and similar technologies.

Supporting quotations

Cookies and similar technologies

We use cookies. Some of these cookies are necessary for the basic functioning of the website and therefore cannot be deactivated. We will use optional cookies only if you have previously consented to such use.

We will save your choices in the form of a cookie. This cookie has a limited effective period of one year.

Qualifications & exceptions

• Necessary cookies cannot be deactivated.
• Optional cookies need prior consent.

Not stated here

• This passage does not repeat that the banner appears for an EEA IP address; whether it appears for Brazil visitors is not stated.

Data Access & Collection · Company practice

Brazil list: job application data is processed to respond; career spaces may be recorded

The list for Brazil says information relating to a job application, like name, email address, employment details, CV, resume or other employment history details, is processed to process and respond to the application. If you engage with Roblox in an immersive space for prospective employees, such as the Roblox Career Center, the space may be recorded to provide the experience.

Supporting quotations

On our corporate websites or in job applications

Information relating to a job application made by you, like your name, email address, employment details, CV, resume or other details of your employment history sent by you.

such a space may be recorded in order to provide the experience

Qualifications & exceptions

• Applies to people who apply for jobs.
• Recording is stated "may".

Not stated here

• How long job application information is kept is not stated.

Use & Processing · Company commitment

Brazil list: no automated decision making with legal or similarly significant effects

The list for Brazil says Roblox does not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

Supporting quotations

Automated Decision-Making

Please note that we do not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

Qualifications & exceptions

• Limited to automated decision making with legal effects or similarly significant effects.

Not stated here

• Whether other automated processing is covered is not stated.

Account & Service Control · Company commitment

Brazil list: under-13 accounts start with privacy-protective settings, without personalized ads and some alerts

The list for Brazil says that when users under 13 register for the Service, their account is automatically set to privacy-protective settings by default, so they will not have access to certain features, including personalized advertising and certain types of notification alerts.

Supporting quotations

Personal Information of Children and Parental Consent

Please note that when users under the age of 13 register for the Service, their account is automatically set to to privacy-protective settings by default. This means that these users will not have access to certain features, including personalized advertising, and certain types of notification alerts.

Qualifications & exceptions

• Applies to users under 13 at registration.

Not stated here

• The full list of unavailable features is not given.

Data Access & Collection · Company practice

Brazil list: child account data is used for access and parent contact; birth date sets features (source wording garbled)

The list for Brazil says that when a child creates an account Roblox may process a username, password, birthdate and gender (gender is optional). It says it may use the parent's email to send a notification about the child's account and an invitation for the parent to review the account and update settings, and may use the birthdate to decide which features the child should have access to and when the child turns 13 and can be given broader access. One sentence in the source reads "Separate from account creation, users may optionally provide the user access to the Service and to communicate with the parent about the child’s account (if a parent email was provided)", which does not read as a complete sentence; it is quoted as written and not repaired. Its parenthetical suggests a parent email is provided in some cases.

Supporting quotations

When a child creates an account on Roblox, we may process a username, password, birthdate, and gender (gender is optional).

Separate from account creation, users may optionally provide the user access to the Service and to communicate with the parent about the child’s account (if a parent email was provided).

For example, we may use the parent’s email to send an email notification about the child’s account and an invitation for the parent to review their child's account and update settings.

We may use the birthdate the child provides when signing up for the Service to determine which features on Roblox the child should have access to and to determine when the child will turn 13 years old and can be given broader access to features on our Service.

Qualifications & exceptions

• Applies to children who create an account.
• Parent communication applies "if a parent email was provided".

Not stated here

• The garbled sentence leaves unclear exactly what users may optionally provide and the stated purpose; the parallel passage for the EEA, UK and Switzerland is not used to fill the gap.

Sharing & Disclosure · Company commitment

Brazil list: child account information is generally used only for stated purposes; parental consent where applicable

The list for Brazil says that in general Roblox will not use or share account information (including Personal Information) from a child's account except for the permissible purposes stated in the Privacy Policy and, where applicable, only with the prior verifiable consent of a parent or legal guardian.

Supporting quotations

In general, we will not use or share account information (including Personal Information) from a child's account except for the permissible purposes stated in this Privacy Policy and, where applicable, only with the prior verifiable consent of a parent or legal guardian.

“Children” or “Child” means any user under the age of 13

Qualifications & exceptions

• The commitment is "in general".
• Parental consent applies "where applicable".

Not stated here

• When parental consent is applicable is not stated.

Sharing & Disclosure · Company practice

Brazil list: service providers receive information for assigned tasks only; illustrative providers listed

The list for Brazil says Roblox may share users' information, including Personal Information like billing information or usernames, with third-party agents, contractors or service providers hired to perform services on its behalf, who may operate or support certain functions of the Service. It gives an illustrative list of functions and providers: account integrity and security (for example Persona), analytics (Google LLC), user acquisition (AppsFlyer), community filtering and moderation, customer support, surveys and promotions (Reach3), billing services and payment gateway providers (Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla), and hosting and content delivery network services (AWS, Equinix, CenturyLink, YouTube, Vimeo). The agents may use the information only for the specific tasks they were hired for, consistent with the Privacy Policy, and Roblox says it takes steps so that service providers with access to Personal Information are capable of protecting it.

Supporting quotations

Data Sharing

Roblox may share users’ information, including Personal Information like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Roblox’s behalf.

Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions:

Account Integrity and Security (e.g., Persona);

Analytics services (e.g., Google LLC);

User Acquisition services (e.g., AppsFlyer);

Community filtering and moderation services;

Customer support services;

Surveys and promotions (e.g., Reach3);

Billing services and payment gateway providers (e.g., Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla); and

Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink, YouTube, Vimeo).

These agents and contractors are only allowed to use the information shared with them only for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes.

Qualifications & exceptions

• The list of providers is "illustrative".
• Providers may use the information only for the tasks they were hired to do.

Not stated here

• Which providers actually receive which information is not stated.

Sharing & Disclosure · Company practice

Brazil list: creators see usernames, user ID, game metrics, UGC details and region; IP address is not shared

The list for Brazil says creators of the experiences you use or content you interact with have access to your username, display name, user ID, game metrics, UGC transaction details and your regional location (based on your IP address), and that Roblox does not share your IP address with creators. Regional location is provided so creators can determine their player base and ensure their experiences meet the legal requirements of the country you live in.

Supporting quotations

the creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators.

We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in.

Qualifications & exceptions

• Applies to creators of the experiences you use or content you interact with.

Not stated here

• What creators may do with this information beyond the stated purposes is not addressed.

Sharing & Disclosure · Company practice

Brazil list: information may be disclosed to advertisers and measurement companies, including identifiers

The list for Brazil says that in accordance with applicable laws Roblox may disclose information collected from or about you to advertisers and/or advertising measurement companies to select advertisements for you or to measure and improve advertising effectiveness. Data disclosed for this purpose includes contact identifiers and device identifiers.

Supporting quotations

In accordance with applicable laws, Roblox may disclose information collected from or about you with advertisers and/or advertising measurement companies to select advertisements for you, or measure and improve advertising effectiveness. Data disclosed for this purpose includes contact identifiers and device identifiers.

Qualifications & exceptions

• Disclosure is "in accordance with applicable laws".
• The data list says "includes".

Not stated here

• This passage does not mention a consent step; the EEA list gives consent as the basis for disclosure to advertising partners.

Charges & Financial Obligations · Company practice

Brazil list: Roblox and a Commerce Provider may exchange purchase information to fulfill a transaction

The list for Brazil says that if you directly interact with a Commerce Provider to purchase a Commerce Product on Roblox, Roblox and the provider may need to exchange information about the purchase to fulfill the transaction, including a transaction identifier that lets each party confirm certain information such as whether a purchase has been completed.

Supporting quotations

If you directly interact with a Commerce Provider to purchase a Commerce Product(s) on Roblox, Roblox and the Commerce Provider may need to exchange information about your purchase in order to fulfill the transaction.

Qualifications & exceptions

• Applies when you interact directly with a Commerce Provider to buy a Commerce Product.

Not stated here

• "Commerce Provider" and "Commerce Product" are not defined in this passage.

Sharing & Disclosure · Permission or license

Brazil list: Roblox may disclose information, including communication content, for legal process and agency requests

The list for Brazil says Roblox may disclose Personal Information, including the content of your communications on the Service, to comply with legal process such as court orders and subpoenas. It may also disclose Personal Information, including content, in response to a request from law enforcement agencies, regulators or other public agencies (including schools or children services) if it believes there is a risk to user safety or security, for legal reasons, or to prevent a crime, in accordance with Section 4 of the policy.

Supporting quotations

Legal disclosure

We may disclose Personal Information about you, including the content of your communications on the Service, to comply with legal process, including court orders and subpoenas, served on our Service.

In addition, we also may disclose Personal Information about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), if we believe that there is a risk to user safety or security, for legal reasons, or to prevent a crime, in accordance with Section 4 of the Roblox Privacy and Cookie Policy.

Qualifications & exceptions

• Agency requests lead to disclosure if Roblox believes there is a risk to user safety or security, for legal reasons, or to prevent a crime.

Not stated here

• "Section 4" is referred to by number; the source does not print section numbers.

Sharing & Disclosure · Company practice

Brazil list: information is stored on US servers; transfers rely on a mechanism set out in Brazilian law

The list for Brazil says Roblox is based in the U.S. and that Personal Information it collects is sent to and stored on secure servers in the United States, which it calls necessary to process the information. Some of its agents and third-party service providers are located outside Brazil, for example in the United States. It says US or other countries' data protection laws may not be as comprehensive or equivalent to those in Brazil. Wherever it transfers Personal Information, it says it will take reasonable steps so that it relies on a legitimate international transfer mechanism, as set out in Brazilian data protection laws.

Supporting quotations

Storage and international transfer of your Personal Information

Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America.

Some of our agents and third-party service providers are located outside of Brazil, e.g. the United States.

Wherever we transfer your Personal Information, we will take reasonable steps so that we rely on a legitimate international transfer mechanism, as set out in Brazilian data protection laws.

Qualifications & exceptions

• Storage is on servers in the United States.

Not stated here

• Which transfer mechanism is used is not stated.

Use & Processing · User right or choice

Brazil list: data subjects may confirm processing, access data, and have it corrected, anonymized, blocked or deleted

The list for Brazil says that as a data subject located in Brazil you have rights regarding your Personal Information, and that Roblox provides mechanisms, detailed below, to exercise them. The rights listed here are to confirm whether Roblox processes your Personal Information; to access it; to correct incomplete, inaccurate or outdated information; and to anonymize, block or delete unnecessary or excessive information or data processed in non-compliance with LGPD. The list continues beyond these items.

Supporting quotations

Your rights as a Data Subject

As a data subject located in Brazil, you have rights regarding your Personal Information.

Confirm whether or not we process your Personal Information

Access your Personal Information

Correct incomplete, inaccurate, or outdated Personal Information

Anonymize, block or delete unnecessary, excessive Personal Information or data processed in non-compliance with LGPD

Qualifications & exceptions

• Applies to data subjects located in Brazil.
• Anonymization, blocking or deletion applies to unnecessary or excessive information or data processed in non-compliance with LGPD.

Not stated here

• LGPD is named but its text is not supplied here.
• The remaining rights and the exercise mechanisms are described after this passage.

Use & Processing · User right or choice

Brazil list: rights also include portability, information on sharing and consent, and withdrawing consent

The list for Brazil continues the rights with: porting your Personal Information to another service provider, upon express request and subject to Roblox's trade secrets, in accordance with the regulations of the supervisory authority; deleting Personal Information processed under your consent if it is withdrawn, when applicable; requesting information about the public and private entities with which Roblox shared your Personal Information; requesting information about the possibility of not providing consent and the consequences; withdrawing your consent, where applicable; requesting information about with whom Roblox shares your Personal Information; and objecting to processing activities that violate LGPD's provisions.

Supporting quotations

Port your Personal Information to another service provider, upon express request and subject to our trade secrets, in accordance with the regulations of the supervisory authority

Delete Personal Information processed under your consent if it is withdrawn, when applicable

Request information about public and private entities with which we shared your Personal Information

Request information about the possibility of not providing consent and about the consequences of doing so

Withdraw your consent, where applicable

Request information about with whom we share your Personal Information

Object to processing activities that violates LGPD’s provisions

Qualifications & exceptions

• Portability is upon express request and subject to trade secrets.
• Deletion on withdrawal and withdrawal of consent apply "when applicable" or "where applicable".

Not stated here

• LGPD and the supervisory authority's regulations are not supplied here.

Account & Service Control · Procedure

Brazil list: Roblox may ask you to confirm your identity and responds only after validating it

The list for Brazil says that before responding to any of your requests, Roblox may ask you for information to confirm your identity, and that it will only respond after validating your identity.

Supporting quotations

Before responding to any of your requests, we may ask you to provide us with some information to confirm your identity. We will only respond to your request after validating your identity.

Qualifications & exceptions

• Applies before Roblox responds to any request.

Not stated here

• What information Roblox may ask for is not stated.

Legal Rights & Agreement Rules · Restriction or exception

Brazil list: rights are not absolute; requests go to the Customer Support Form and appeals to the Brazilian DPO

The list for Brazil says these rights are not absolute and may not apply in certain circumstances. For example, Roblox may continue to process and retain Personal Information despite a request to delete, object, block or anonymize it, to comply with legal, contractual and/or regulatory obligations, to protect and exercise rights, including in judicial, administrative and arbitration proceedings, and as otherwise required by law. To exercise your rights or ask questions you can use the Customer Support Form. To appeal a decision about your privacy rights you can contact the Brazilian Data Protection Officer by email, or reach Roblox as described in Section 1.

Supporting quotations

Please also note that these rights are not absolute and may not apply in certain circumstances. For example, we may continue to process and retain Personal Information regardless of your request to delete, object, block or anonymize it, to comply with legal, contractual and/or regulatory obligations, and to protect and exercise rights, including in judicial, administrative and arbitration proceedings, and as otherwise required by law.

To exercise your rights or ask questions, you can contact us by completing this Customer Support Form.

To appeal a decision about your privacy rights, please contact our Brazilian Data Protection Officer by emailing

Qualifications & exceptions

• The rights are not absolute.
• Roblox may keep processing for legal, contractual and regulatory obligations and for protecting and exercising rights.

Not stated here

• The Customer Support Form is linked but its text is not supplied here.
• "Section 1" is referred to by number; the source does not print section numbers.

Legal Rights & Agreement Rules · Context

The page lists downloadable PDF versions in many languages, with file names carrying dates

The page lists downloadable PDF attachments of the policy in Arabic, German, English (US), Spanish, French, Indonesian, Italian, Japanese, Korean, Dutch, Polish, Brazilian Portuguese, Thai, Turkish, Vietnamese and Simplified Chinese. The English (US) file name carries 20261101, matching the stated effective date. The Arabic and Dutch file names also carry 20261101, while the other listed translations carry 20260430. The text of these PDFs is not part of the supplied source, so the card cannot say what they contain or whether the translations differ from the English text; the policy says the English version controls if there is a material or perceived conflict with a translation.

Supporting quotations

AR - سياسة الخصوصية وملفات تعريف الارتباط الخاصة بـ Roblox 20261101.pdf

DE - Roblox-Datenschutz- und Cookie-Richtlinie 20260430.pdf

EN-US - Roblox Privacy and Cookie Policy 20261101.pdf

NL - Privacy- en cookiebeleid van Roblox 20261101.pdf

Privacidade e de Cookies da Roblox 20260430.pdf

ZH-CN - Roblox 隐私和 Cookie 政策 20260430.pdf

Qualifications & exceptions

• The dates are taken from file names only.
• The English version controls in a conflict with a translation.

Not stated here

• The PDFs' text is not supplied here.
• Why some translations carry an earlier date in their file names is not stated.

Legal Rights & Agreement Rules · Context

More PDF versions are listed for Chinese (Traditional) and Indian languages, mostly with file names dated 20260430

The page continues its list of downloadable PDF attachments with Traditional Chinese, Hindi, Malayalam, Kannada, Marathi, Telugu and Tamil versions whose file names carry 20260430, and a Bengali (India) version whose file name carries 20261101. The text of these PDFs is not part of the supplied source, so the card cannot say what they contain or whether they differ from the English text; the policy says the English version controls if there is a material or perceived conflict with a translation.

Supporting quotations

ZH-TW - Roblox 隱私權和 Cookie 政策 20260430.pdf

HI - Roblox की प्राइवेसी और कुकी पॉलिसी 20260430.pdf

ML - Roblox സ്വകാര്യതാ കുക്കി നയം 20260430.pdf

KN - Roblox ಗೌಪ್ಯತೆ ಮತ್ತು ಕುಕೀ ನೀತಿ 20260430.pdf

MR - Roblox गोपनीयता आणि कुकी धोरण 20260430.pdf

TE - Roblox గోప్యత మరియు కుకీ విధానం 20260430.pdf

TA - Roblox தனியுரிமை மற்றும் குக்கீ கொள்கை 20260430.pdf

BN-IN - Roblox গোপনীয়তা নীতি এবং কুকি পলিসি 20261101.pdf

Qualifications & exceptions

• The dates are taken from file names only.
• The English version controls in a conflict with a translation.

Not stated here

• The PDFs' text is not supplied here.
• Why file name dates differ is not stated.

Legal Rights & Agreement Rules · Context

More PDF versions are listed for European languages, with file names dated 20261101

The page continues its list of downloadable PDF attachments with Bulgarian, Croatian, Czech, Danish, Estonian, Finnish, Greek, Hungarian, Irish, Latvian, Lithuanian, Maltese, Portuguese and Romanian versions whose file names all carry 20261101. The text of these PDFs is not part of the supplied source, so the card cannot say what they contain or whether they differ from the English text; the policy says the English version controls if there is a material or perceived conflict with a translation.

Supporting quotations

BG-BG - Политиката за поверителност и бисквитки на Roblox 20261101.pdf

HR-HR - Robloxova Pravila o privatnosti i kolačićima 20261101.pdf

CS - Zásady ochrany osobních údajů a souborů cookie Robloxu 20261101.pdf

DA - privatlivs- og cookie-politik for Roblox 20261101.pdf

ET - Robloxi privaatsus- ja küpsisepoliitikat 20261101.pdf

FI - Robloxin tietosuoja- ja evästekäytäntöä 20261101.pdf

EL - Πολιτική απορρήτου και Cookie του Roblox 20261101.pdf

HU-HU - Roblox Adatvédelmi és cookie-kra vonatkozó szabályzatát 20261101.pdf

GA - Polasaí Príobháideachta agus Fianán Roblox 20261101.pdf

LV-LV - „Roblox” privātuma un sīkdatņu politiku 20261101.pdf

LT-LT - „Roblox“ privatumo ir slapukų politiką 20261101.pdf

MT - Politika tagħna ta' Roblox dwar il-Privatezza u l-Cookie 20261101.pdf

PT - Política de Privacidade e Cookies do Roblox 20261101.pdf

RO-RO - Politica de confidențialitate și cookie-uri Roblox 20261101.pdf

Qualifications & exceptions

• The dates are taken from file names only.
• The English version controls in a conflict with a translation.

Not stated here

• The PDFs' text is not supplied here.

Legal Rights & Agreement Rules · Context

The last listed PDF versions include UK English and further translations, all with file names dated 20261101

The page ends its list of downloadable PDF attachments with Slovak, Slovenian, Spanish (Spain), Swedish, Telugu, English (UK), Tamil and Hindi versions whose file names carry 20261101. The Telugu, Tamil and Hindi entries repeat languages listed earlier with file names dated 20260430, so those languages appear twice with different dates. The text of these PDFs is not part of the supplied source, so the card cannot say what they contain or whether the UK English version differs from the English (US) text; the policy says the English version controls if there is a material or perceived conflict with a translation.

Supporting quotations

SK-SK - Zásady ochrany osobných údajov a súborov cookie Roblox 20261101.pdf

SL-SI - Pravilnik o zasebnosti in piškotkih družbe Roblox 20261101.pdf

ES-ES - Política de privacidad y de cookies de Roblox 20261101.pdf

SV - Roblox integritets- och cookiepolicy 20261101.pdf

TE - Roblox గోప్యతా మరియు కుకీల పాలసీని 20261101.pdf

EN-GB - Roblox Privacy and Cookie Policy 20261101.pdf

TA - Roblox தனியுரிமை மற்றும் குக்கீ கொள்கையை 20261101.pdf

HI - Roblox प्राइवेसी और कुकी पॉलिसी 20261101.pdf

Qualifications & exceptions

• The dates are taken from file names only.
• The English version controls in a conflict with a translation.

Not stated here

• The PDFs' text is not supplied here.
• Which of the two Telugu, Tamil and Hindi entries is current is not stated.