ROBLOX PRIVACY POLICY

About ROBLOX

ROBLOX is an online virtual world and building game for kids. ROBLOX works like this:

• a user creates a virtual character, that is his or her identity in the ROBLOX world
• users interact with other users through in-game chat, personal messaging (site contained), and user forums; privacy settings allow users or parents to restrict communications with other users
• each user is given one or more pieces of virtual real estate on which they can build houses, cars, machines, or anything else you can build with building blocks; these places are called “games”
• users search for, find, and play games made by other users; they play these games with other users from around the world, and are identified only by their virtual character name
• users earn tickets and/or GOLDBUX, our virtual currency; users earn these in a variety of ways, and use them to buy items for their characters, including virtual hats, shirts, and pants; users can also sell these items, earning tickets and/or GOLDBUX
• users can purchase premium services, including: Builder’s Club, a monthly subscription that grants the user more virtual places and a daily allowance, among other things; and, GOLDBUX currency, allowing users to buy virtual currency that can in turn be used to buy virtual goods

Requested Information

ROBLOX users may play as guests; in this mode, users remain anonymous and interact with the website and game in Super Safe Mode – no free chat, no personal messaging to or from users, no posting to the forums, and other restrictions designed to prevent users from sharing personal information, intentional or otherwise. As guests, users are unable to save play statistics, accumulate points, share models, or participate in our virtual economy.

Users wishing to save statistics, share models, and participate in the economy are required to enter a username and password. We advise users to create a username that does not reflect their own name nor reveal personally identifiable information. We also advise users to pick a password that is not easy to guess, and to not share that password. For security reasons, we store passwords in encrypted form.

Registered users who are under 13 initially play in Super Safe Mode. To opt-in to free (but filtered) text communications, users are required to provide and verify a parent’s email address. We use this information to inform parents that their child has signed up to use our service; we also use this information to obtain consent from the parent regarding their child’s continued use of the site. The verification email we send informs parents of their child’s registration with ROBLOX and provides access to a parental control panel (parent’s may also create parental controls at any time). Under-13 users who do not enter a parent’s email address or who fail to verify one remain in Super Safe Mode. Registered users who are 13 or older can opt-in to Super Safe Mode, but begin with it turned off.

Regardless of security and privacy settings, all text on the site is filtered proactively to remove references to addresses, emails, phone numbers, age, and other personally identifiable information. All text is also filtered for profanity, phishing, and adult or suggestive content. Our system is a combination human and automated processes; like all filtering technology, our processes are not 100% effective.

Users wishing to purchase Builder’s Club or GOLDBUX are required to enter billing information, including name, billing address, credit card or PayPal number, and billing email. For children under 13, we request the parent’s billing information. Billing information is retained to support customer service inquiries, but we do not retain the full credit card number.

If you (or your child) choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site; ROBLOX does not store this information.

We do not collect any Personal Information from children only username and password. We do not ask for and collect from a kid under 13 personally identifiable information that is reasonably necessary for that kid to participate in any given activity online

Collected Information

ROBLOX uses a software technology called “cookies.” Cookies are small text files that we place in visitors’ computer browsers to store their preferences. These cookies do not store personally identifiable information. For account security purposes, we may store a cookie that contains the encrypted user password; the original password cannot be recovered by hackers. Users who disable cookies in their browsers will not be able to logon to the ROBLOX website or play the ROBLOX game.

We also use cookies and “clear gifs” (on-page tracking code) to track user entry onto and movement within the ROBLOX website. This helps us credit advertisers appropriately, and measure the health and effectiveness of our website. For example, we use tracking to determine if new page designs are user friendly or too complicated. Our tracking approach is industry standard, and includes non-personally identifiable information such as IP address, browser type, and date/time.

Additionally, when visitors come to our site, we automatically collect some non-personally identifiable “computer” information, such as the type of computer operating system (e.g., Windows 95 or Mac OS), the web browser (e.g., Netscape, Internet Explorer) being used, IP address, and information regarding the Internet service provider. This information is used to provide technical and community support.

We also collect performance data from within ROBLOX Studio or the ROBLOX Player. We use this data retrospectively to improve the user experience of our games. This information includes in-game networking activity, CPU load, and resource usage, among other relevant data.

Some of our business partners (e.g., advertisers) use cookies on our site. We have no access to or control over these cookies. This privacy statement covers the use of cookies by ROBLOX (www.roblox.com) only and does not cover the use of cookies by any advertisers.

Information Sharing

We pass user billing information on to PayPal, our transaction processing partner. This is done for all payment types, including credit card and PayPal payments. For recurring monthly transactions, PayPal retains the credit card authorization on file, but we do not. All transactions are processed by PayPal.

We share aggregate web activity data, such as page views and unique visitor counts, with our advertising partners. No personally identifiable information is shared.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

We will not use or transfer personally identifiable information in ways that are materially different from the ones described above without also providing parental notification of such practices and obtaining consent for any materially different uses.

Security & Privacy

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you use a bulletin board, blog, or chat room on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Options for Parents

Parents can set up a parental control panel to manage the privacy settings of their children. If a child enters a parent’s email address during signup, the parent receives an email notification of the account creation and an invitation to establish a control panel for that account. Parents can also create a control panel at any time and attach it to a child’s existing account.

A parent receiving a verification email has three options. First, the parent can choose not to respond; in this case, the child remains in Super Safe Mode. Second, the parent can choose to click the link in the email and do nothing more; in this case, the child is opted-in to free (but filtered) text communications, including free-text chat and personal messaging (site limited), forum posts, and site commentary. Third, the parent can choose to click the link in the email and then create a parental control account; in this case, the parent can set fine-grained security and privacy options.

Parents can close a child’s account by contacting ROBLOX customer service (see below). This hides the account from all other ROBLOX users and outside parties. The account data is not deleted, but retained internally for three purposes. Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries. Public domain content is retained for use by the community – e.g. a virtual shirt sold by the child to another user is kept in the system because the recipient now “owns” a copy of that article. Finally, user account history is retained to support subsequent customer service inquiries. All retained data for a closed account is private and visible only to employees.

Updating/Accessing/Amending/Correcting Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, or deactivate it by making the change on our member information page (or by emailing our Customer Support at info@roblox.com) or by contacting us by telephone or postal mail at the contact information listed below.

TRUSTe Children’s Online Privacy Seal Program

ROBLOX is a licensee of the TRUSTe Children’s Online Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the site www.roblox.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact the ROBLOX Privacy Manager at (888) 858-BLOX. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.

The TRUSTe Children’s Online Privacy Seal Program covers only Personal Information that is collected through this Web site, and does not cover Personal Information that may be collected through software downloaded from this site.

Privacy Policy Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to how we use Personal Information regarding parents. We will notify you by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.

Contact Information

If you have any questions, comments, or concerns regarding our privacy policy and/or practices, please contact us at the following e-mail address, telephone number, or address:

ROBLOX Privacy Manager
(888) 858-BLOX
info@roblox.com
600 Allerton Street, Suite 102
Redwood City, CA 94063

Glossary of Terms

Privacy

Super Safe Play Mode – users in this mode cannot free-chat, send or receive personal messages to or from other users, post to forums, or edit any free-text field

Communications

Personal Messaging – user-to-user and ROBLOX-to-user messaging inside the ROBLOX website
In-Game Chat – user-to-user messaging inside the ROBLOX game client
Forums – user and staff collaborative help and interest forums
Wiki – user and staff collaborative help and tutorial pages

Moderation

Text Filtering – all user-generated text is pre-filtered for inappropriate content
Text Filtering Black List – list of inappropriate keywords and word patterns
Image Moderation – all images are pre-filtered by human moderators
Abuse Reports – all users and content can be reported for abuse or inappropriateness

Relevant Dates

Effective Date – December 12, 2008
Last Updated – December 11, 2008