I am writing this today to seek clarification on a particular aspect of the ROBLOX Terms of Service (ToS) relating to user data privacy and collection.
In my profession, I adhere strictly to privacy and data security principles, including but not limited to the secure handling and storage of personally identifiable information (PII). I am currently working on a project that, for its optimal functionality, would require the collection of a user’s phone number. The purpose of this collection is to enable the sending of push notifications, subject to the user’s explicit consent.
I am aware that the ToS and the Roblox Creator Agreement explicitly prohibit the collection of personal data from users. Furthermore, they forbid the use of such data to provide services to any third party, build profiles or similar records on any individual user, associate the behavior of any individual device or browser with any segment, profile, or similar record, associate any data of users with any other personal information of the user, or sell, disclose, share, rent, lease, syndicate, modify, reverse engineer, decompile, lend, or otherwise alter any user’s PII1.
In my proposed use case, however, I believe that the collection of phone numbers does not fall into any of the above categories. This data would be kept secure, following the industry’s best practices for data security, and would be used solely for the purpose of sending push notifications upon the explicit consent of the user.
I am also aware that the legal framework surrounding data collection requires informed consent. In order to ensure full compliance, I am prepared to consult with a legal professional who can assist in the drafting of a comprehensive document that informs users of what they are agreeing to when they consent to this data collection.
So, with this, can I collect this specific user data to achieve what I am trying to do on this platform?
I realize I may need a ROBLOX Admin or the legal team to answer this question.