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Mobile App Manual Review under COPPA Rule: ‘Roblox'

Nov 23, 2023 12:30:00 PM

Welcome to Pixalate’s CTV & Mobile App Manual Reviews According to COPPA, a series containing the detailed factors the Trust & Safety Advisory Board educators used to assess an app’s child-directedness.

The educators manually review thousands of mobile apps available in the Google Play & Apple App Stores as well as connected TV (CTV) apps from the Roku Channel Store and Amazon Fire TV App Store using the COPPA Rule factors shown below & make those results available to the public at ratings.pixalate.com.

This post takes a look at a game which is available from the Google Play & Apple App Store. Our reviewer discusses how the subjective factors set forth in the COPPA Rule apply to the app and factor into the reviewer's determination as to whether the app is child-directed or general audience (i.e., it is not targeting children).

Manually reviewed in this post


The 10 COPPA Rule factors

The teacher will indicate the factors they relied upon in their assessment using the 10 factors shown below that reflect the 10 child-directed factors in the COPPA Rule.

Reviewed by: Emma Burdis


Manual Review: Roblox

Likely audience after manual review

  • Google Developer: Roblox Corporation
  • Apple Developer: Roblox Corporation
  • Google Bundle ID: com.roblox.client
  • Apple Bundle ID: 431946152
  • Privacy Policy
  • Emma’s Take: Roblox is a huge platform for mini-games and micro-transactions, hugely appealing to kids but some adults also play.

COPPA factors used to determine audience

Roblox is a huge online hub that provides its users access to over 40 million games and experiences. These games are mostly created by the users themselves using the Roblox Studio. The games likely cover most topics that you could think of, with many of them being roleplay games (such as Brookhaven or Adopt Me), obstacle course games (referred to as hobbies), or horror-based story games (such as Rainbow Friends). The games are simple to launch and can be played easily on tablets or phones as well as desktop computers. Users must sign up for an account in order to play. As part of this process, their date of birth is required. 

Roblox has built its empire on the use of in-game microtransactions using its own currency, Robux. Robux cannot be earned through playing, only bought using real money or by selling your creations on the marketplace. Robux can be used for in-game passes or accessories, or purchasing clothes or other items for your avatar. There are endless amounts of items which are available to buy and the motivation to collect more items is a strong motivation for the players. There is also the option to become a Premium member, where you pay a subscription fee that gives you access to an allowance of Robux each month plus the Premium symbol displayed next to your username. 

In the third quarter of 2023, Roblox had over 29 million daily users under the age of 13, according to Statista.com.


Roblox has a comprehensive, 28-page policy to explain how they handle users’ information. The first main section is entitled “Are you under 13 or responsible for an under-13-year-old?”  The policy is written directly to the reader: “This part of the privacy policy is just for you.” This section details that children should ask for permission before playing and set limits for communicating with others. It goes on to explain what information is collected from them and how it is used. Having this child-directed section featured so prominently in the Privacy Policy is another factor pointing Roblox toward the Mixed Audience classification.

Screenshots of Roblox

About Pixalate’s Trust & Safety Advisory Board

Pixalate’s Trust and Safety Advisory Board was created to bring in individuals with experience using child-directed apps in the classroom to review and assess which apps are child-directed. This manual review process serves to quality check Pixalate’s automated review process. See our full methodology for more information.


This blog post published by Pixalate is available for informational purposes only and is not considered legal advice. By viewing this blog post, the reader understands and agrees that there is no attorney-client relationship between the reader and the blog publisher. The blog should not be used as a substitute for legal advice from a licensed professional attorney in the applicable jurisdiction(s), and readers are urged to consult their own legal counsel on any specific legal questions concerning any specific situation. The content of this blog post reflects Pixalate's opinions with respect to factors that Pixalate believes may be useful to the digital media industry. Pixalate's opinions are just that, opinions, which means that they are neither facts nor guarantees; and this blog post is not intended to impugn the standing or reputation of any entity, person or app, but instead, to report findings pertaining to mobile and Connected TV (CTV) apps.

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