Translation Service
What They Say
Roblox's policy includes a dedicated section on children's privacy and COPPA compliance. They state that users under 13 have restricted chat and privacy settings by default, that parental consent is required for account creation, and that they do not serve interest-based ads to users under 13. The child safety language is prominent and has clearly been written with legal compliance as the primary objective.
What They Mean
67% of Roblox's user base is under 16. The platform collects device identifiers, behavioural data, purchase history, and social graph information from children at scale. Robux — Roblox's virtual currency purchased with real money — creates a purchase history database for minor users. The virtual economy is designed with mechanics that encourage repeated small purchases (the Bureau identifies these as gambling-adjacent in structure). The social graph of a child's Roblox friends is a sensitive database that includes who their real-world friends are, how they spend their time, and their digital behaviour patterns — held by a company whose fundamental product is attention capture for minors.
Worst Clause — Exhibit A
"Roblox may share personal information with third-party companies that provide services to us, such as website analytics, payment processing, and customer service. These third parties are permitted to use your personal information only to help Roblox provide services to you."
Bureau Translation:
Third parties with access to children's device data for 'website analytics' means analytics companies receive identifiable device data about minors. The clause that 'third parties are permitted to use your personal information only to help Roblox' defines permitted use so broadly — website analytics encompasses most data processing — that it provides minimal protection. The Bureau considers the use of children's behavioural data by third-party analytics companies to be the most concerning element of Roblox's data architecture.
Evidence Tags — Data Collected
Bureau Verdict
"Roblox is the Bureau's lowest-graded platform. A service whose majority user base consists of children under 16, collecting device data, purchase history, social graphs, and behavioural patterns from minors, operating a virtual economy with mechanics that structurally resemble gambling, and sharing data with third-party analytics companies, represents the most serious privacy concern in our archive. Grade F. The Bureau recommends parental review of account settings, purchase limits, and chat permissions for all Roblox accounts held by minors."
Overall Grade
Child-Friendly Language, Adult-Scale Collection
Frequently Asked Questions
Dark Patterns Documented
See the full Dark Pattern Encyclopedia for documentation of each technique.
Audited: 2026-03-20