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.

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.

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.

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. If you live in the United States If you live in the United States, please visit our US State Privacy Policy Addendum for more information. 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 . 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: 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"). 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. 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. 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. 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"). 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. 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. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). 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"). Posting content Comments or messages you post or transmit on Roblox via public chats, forums, group walls, personal post, etc. 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. Asking questions or getting technical support Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. 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. 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. 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. The bases for data are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") GDPR and Article 6 sec. 1 sent. 1 lit. f ("legitimate interest"). 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"). 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"). 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. The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"). 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. Information required for additional features that require the use of your camera or upload content, including photos or video, that contains your Personal Information. If you decide to use these features and upload content that requires the use of your camera or upload content that contains your Personal Information, we will collect, process, and store that content only for as long as needed to accomplish the purpose of the feature. The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"). 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"). For more information, please refer to the Roblox Facial Animation Privacy Notice and Roblox Facial Media Capture Privacy Notice . 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. The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"). 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. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). Interacting with our experiences. 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. For example, we may collect information from a user's 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 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. The bases for processing this Personal Information are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and f ("legitimate interest"). 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"). 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. To the extent these practices involve the processing of Personal Information and displaying personalized ads, 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"). 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"). 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"). 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"). 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. The basis for processing this Personal Information is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). 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"). 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. 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"). 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. If you engage with Roblox in an immersive space for prospective employees, such as the Roblox Career Center, such a space may be recorded in order to provide the experience. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("necessary for entering into an employment contract with us"). 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. 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. These providers may operate or support certain functions of the Service. 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. Roblox takes steps such that all service providers with access to Personal Information are capable of protecting the information we share with them. Further, 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. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b ("performance of a contract"), 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") GDPR. It is the creators' legitimate interest to comply with non-EEA legal obligations. 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"). 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. This involves Roblox or the Commerce Provider creating a transaction identifier that allows each party to confirm certain information about the transaction, such as whether a purchase has been completed. 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"). 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, for example, where consistent with Roblox's obligations under the Digital Services Act, Article 18 and Information notices issued under the UK Online Safety Act. 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. The legal basis for such disclosure is 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") GDPR. It is our legitimate interest to comply with the legal requirements of U.S. law. Further, we have a legitimate interest in these purposes. Storage and international transfer of your Personal Information Roblox is based in the U.S. Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information. Some of our agents and third-party service providers are located outside the European Economic Area, e.g. the United States. 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 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. 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; 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. In this case, please provide us with information about your particular situation. 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. 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. 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: 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. 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. 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. 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. 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. 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. Posting content Comments or messages you post or transmit on Roblox via public chats, forums, group walls, personal post, etc. 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. Asking questions or getting technical support Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. 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. 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. 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. 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. 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. 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 . Information required for additional features that require the use of your camera or upload content, including photos or videos, that contains your Personal Information. 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. For more information, please refer to the Roblox Facial Animation Privacy Notice and Roblox Facial Media Capture Privacy Notice . 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. 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. Interacting with our experiences. 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. For example, we may collect information from a user's 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 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. 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. 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. 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. 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. If you engage with Roblox in an immersive space for prospective employees, such as the Roblox Career Center, such a space may be recorded in order to provide the experience. We will process this information to process and respond to your job application. 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. 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. These providers may operate or support certain functions of the Service. 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. Roblox takes steps such that all service providers with access to Personal Information are capable of protecting the information we share with them. Further, 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. 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. 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. This involves Roblox or the Commerce Provider creating a transaction identifier that allows each party to confirm certain information about the transaction, such as whether a purchase has been completed. 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. Storage and international transfer of your Personal Information Roblox is based in the U.S. Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information. Some of our agents and third-party service providers are located outside of Brazil, e.g. the United States. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in Brazil. 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. Your rights as a Data Subject As a data subject located in Brazil, you have rights regarding your Personal Information. We provide mechanisms, as detailed below, so that you have clarity and transparency in exercising your rights. As a data subject, you have the following rights: 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 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 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. 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 dpo.roblox@leonardi.adv.br , or otherwise reaching out to us as described in Section 1.

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.

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: