Privacy Policy

Introduction

This Privacy Policy describes how Rotector ("we", "our", "us") collects, uses, and shares personal data in connection with our detection system, our review and appeals process, and the rotector.com website. Most of the data we hold is about accounts we have flagged, not about people who come to this site.

Important: Rotector is a volunteer-run, community-driven project and is not affiliated with, endorsed by, or sponsored by Roblox Corporation or Discord Inc.

Who Is Responsible for This Data

Rotector is the data controller for the processing described in this policy. We decide what is collected, why it is collected, and how long it is kept. We make our findings available to people in the United Kingdom and the European Economic Area, and we apply GDPR and UK GDPR to everything described here regardless of where a data subject lives.

Appeals and data-rights requests reach us by email at contact@rayward.app.

Who We Process Data About

We split data subjects into groups because the legal basis, retention, and rights look different for each. The rest of this policy is structured around these groups.

• Flagged Roblox accounts and the Roblox groups they belong to. The accounts the detection system has classified as participating in inappropriate conduct on Roblox.
• Flagged Discord accounts. Discord identities linked to a flagged Roblox account or observed in a server that participates in our reporting program.
• People who contact us. Anyone who opens an appeal, sends a report, or asks us a question.
• Volunteer applicants and reviewers. People who apply to a volunteer role, and the people who carry out reviews.

Flagged Accounts

What a flag is and is not

A flag is our record that an account's public conduct broke platform rules, and that a reviewer on our team agreed with that assessment. It is not a finding of criminal conduct, and it must not be presented or acted on as though it were one. No flag is drawn from a criminal record, a police source, a court record, or any official register. Some of the categories we record describe conduct that could also be unlawful; that does not turn a flag into a legal finding, and we do not process criminal-offence data within the meaning of Article 10.

A flag records conduct, never a characteristic of the person. We do not collect, and do not knowingly hold, data revealing racial or ethnic origin, political opinions, religious belief, health, or sexual orientation.

The reason text attached to a flag is our own statement about an account, not the account holder's. That means it is our responsibility to correct it if it is wrong, and a rectification request is the way to tell us so.

What we hold

• Public profile data: usernames, display names, descriptions, avatars, friend lists, group memberships, and other publicly visible profile fields.
• Group and game data: public membership in groups we have classified, and public participation signals from games tracked for safety reasons.
• Data from properties we operate: server-side activity generated on Roblox properties we run ourselves.
• Flag metadata: classification reason and supporting context, confidence score, evidence references, and the reviewer who confirmed the flag.
• Condo-server membership: whether an account has been observed in Discord servers we have classified as condo servers, recorded as a membership signal rather than as anything the account said.
• Discord identity linkage: Discord user IDs, usernames, and avatars where they have been observed linked to a flagged Roblox account.
• Appeals records: the messages exchanged during any appeal, including the subject's own statements.

We do not access direct messages on either Roblox or Discord, we do not retain the contents of anyone's messages, and we do not collect or store credentials.

Lawful basis

Article 6(1)(f) of GDPR / UK GDPR: legitimate interests of a third party, namely the protection of children on the platforms we observe.

Retention

A flag record is kept while the legitimate-interest balance continues to support it, and we re-examine that balance whenever someone asks us to. We do not keep a flag on a fixed timer, because a flag that is still accurate is still useful and a flag that is no longer accurate should go regardless of its age. Where we are made aware that Roblox has deleted an account, we redact our record so the flag is no longer visible.

How we inform you

We collect this data from public sources and from platforms rather than from you, so Article 14 of GDPR / UK GDPR governs how we are required to tell you about it. We hold no contact details for the accounts a flag concerns. Obtaining them in order to write to each account individually would be impossible or a disproportionate effort within the meaning of Article 14(5)(b), and we rely on that exemption. What we do instead is publish this policy openly, without a login and without a paywall, and operate an appeals route that anyone can reach without an account.

How Our Findings Reach Other People

Our findings are made available through Rayward, a separate service that also carries findings from other detection initiatives. Rotector does not own or operate Rayward. Rayward receives the flag records described above so that approved organisations can act on them. Those organisations receive flag records only; they do not receive support conversations or volunteer application data.

Access to Rayward is granted per account and by application. It is not a public lookup, and it is not available anonymously.

A flag that we clear, redact, or correct is updated in what we make available. If you have a complaint about how a finding of ours was presented or acted on, we deal with it as an appeal against the finding itself, by the route described below.

People Who Write to Us

What we hold

• The contents of your correspondence: everything you write to us, including anything you attach.
• Whatever you use to identify yourself: typically a Roblox account, and the email address you write from.
• The outcome: what a reviewer decided, and when.

Please do not attach anything you would not want a reviewer to read. If you send us material about a third party, we hold it under the same terms as everything else in this policy.

Verifying who you are

Before we act on a request about a specific account, we need to know you control it. For a Roblox account, the usual method is a short phrase we generate and ask you to place temporarily in the account's profile. We ask for the least we can get away with, and we do not ask for identity documents.

Lawful basis and retention

Article 6(1)(f): our legitimate interest in answering you, keeping a record of what was decided, and preventing abuse of the appeals route. Correspondence is kept while it is useful for that purpose and for handling any repeat or related request.

If an address or an account has been blocked from contacting us, we keep that block, because a block anyone could lift by asking would not be a block. We store it as a one-way hash rather than the address itself, alongside a record of what a reviewer decided and when, without a copy of what was written.

Reviews and appeals

Where you believe a flag affecting you is wrong, you can ask for it to be looked at again. Where Article 22 of GDPR / UK GDPR applies to a decision our system makes about you, you have the right to obtain human intervention, to express your point of view, and to contest the decision.

No decision that results in a flag is made by automation alone. The detection system proposes; a reviewer decides. Appeals are read and answered by people, not by an automated assistant.

• You write to contact@rayward.app and say which account is affected.
• We verify that you control it, as described above.
• A reviewer who was not the one who confirmed the original flag looks at the record again.
• We tell you the outcome and the reason for it. Where explaining the reasoning in full would expose detection methods or another person's data, we say so rather than leaving you without an answer.

If an appeal succeeds, the flag stops being served. We keep a minimal internal record that the account was reviewed and cleared, so that the same account is not re-flagged on the same evidence. On a verified erasure request that we grant, that record goes too.

Appeals are usually faster than a rights request. We are a volunteer team and we would rather give you a real answer late than a fast one that is wrong.

Volunteer Reviewers and Applicants

Reviewers see material about identifiable people, including minors. That access carries obligations.

• Reviewers may use what they see only to carry out a review. They may not republish it, share it outside the team, or use it to contact, confront, or identify anybody.
• Those obligations continue after a reviewer leaves the team.
• Access is granted per person, restricted to what the role requires, logged, and revoked when the role ends.
• We revoke access immediately where we believe it has been misused, and we do not need to prove it to a criminal standard first.

For applicants, we hold what you put in your application and our notes on it, under Article 6(1)(f), for as long as the application is live and for a reasonable period afterwards so we can recognise a repeat applicant. Ask us and we will delete it.

We screen the written parts of an application for spam and abuse using a model we run ourselves. That screening can mark an application for closer attention; it cannot reject one. A person reads every application either way.

Service Providers

We keep the list of third parties who touch personal data as short as we can.

• Cloudflare: hosts our edge infrastructure, including request routing, storage, and security. Receives request traffic and IP addresses.
• Rayward: receives appeal and rights correspondence sent to contact@rayward.app, compiles it, and forwards the items concerning Rotector to us. It handles that correspondence on our instructions and for no other purpose. Rotector remains the sole data controller for it.

Our models run on hardware we operate. Neither the detection pipeline nor the application screening described above sends data to a third-party AI provider. Nothing we hold about a flagged account, and nothing you write to us, is passed to an external model.

Information Sharing

We do not sell, rent, or trade personal data. We share information in these limited circumstances:

• Through Rayward, to the approved organisations described above.
• Legal process: to comply with a binding subpoena, warrant, court order, or equivalent legal demand.
• Voluntary disclosure to law enforcement or platform safety teams in cases involving an articulable, current risk to a child. Such disclosures are reviewed internally and logged.
• Service providers: to the providers named above, under data-processing terms that bind them to confidentiality and data-protection obligations.
• Aggregate reporting: we publish aggregate counts and statistics; these contain no personal data.

We do not disclose data to private investigators, journalists, or curious third parties, regardless of who they say they represent, absent a court order.

Public Statistics

We publish running totals about our own work: how many accounts and groups we have flagged, confirmed, or cleared, and how those break down by category. These are counts only. They identify nobody, they cannot be resolved back to an individual account, and they are the only data surface on this site that anyone can read without asking us.

Your Rights

Depending on where you live, you have some or all of the following rights over the data we hold about you:

• Access: a copy of what we hold and a description of how we use it (Article 15 of GDPR / UK GDPR).
• Rectification: correction of inaccurate data (Article 16).
• Erasure: deletion, subject to the limited exemptions in Article 17(3) of GDPR / UK GDPR and the additional exemptions for UK subjects under the Data Protection Act 2018.
• Restriction of processing: a pause on processing while a question is being resolved (Article 18). For flagged Roblox accounts, this is operationalised as a Redacted flag.
• Objection: the right to object to processing under Article 21(1).
• Portability: for data we hold under contract or consent, the right to receive it in a portable format (Article 20).

The route for any of these rights is contact@rayward.app. State which right you are exercising and the account or accounts at issue. We aim to respond within one month of verifying the request, as Article 12(3) requires, and we will tell you if a complex request needs longer. We prioritise parental requests on minor accounts and confirmed false-positive flags.

UK and EU residents retain the right to lodge a complaint with their local supervisory authority. Canadian residents outside Quebec: where PIPEDA applies, we honour the rights it provides. Where other privacy laws apply to data we hold about you (such as US state privacy laws, Australia's Privacy Act, or other regional regulations), we honour the rights they provide on a verified request.

Children's Privacy

Some flagged Roblox accounts are operated by minors. We treat erasure requests from a verified parent or guardian on a minor's flagged account as presumptively granted. We will explain only when we cannot act, and we will not silently refuse.

Our volunteer applications are intended for people 13 and older. We do not knowingly accept applications from children under 13. If you believe a child under 13 has applied, contact us and we will delete their record.

For under-13 Roblox subjects, our processing is bounded to data we have a lawful basis to hold and is not used or disclosed for any unrelated commercial purpose. COPPA governs the collection of children's information by US online services, and we treat the applicability of its specific exceptions to a third-party safety classifier of our shape as counsel-reviewed.

Storage, Transfers, and Changes

Our database and primary infrastructure are located in the European Union. Data in transit is encrypted using TLS. Data at rest is encrypted by the underlying database host. Access to subject-identifiable data is restricted to people with an operational reason to see it, and access is logged.

If we discover a breach affecting personal data, we will notify the relevant supervisory authority or authorities within 72 hours of becoming aware of it, as required by Article 33. Where the breach is likely to result in a high risk to your rights and freedoms, we will notify affected people directly under Article 34, to the extent we have a way to reach them.

We update this Privacy Policy when our processing changes, when a new sub-processor is added, or when guidance from supervisory authorities makes a clarification useful. Changes take effect on posting with a revised "Last Updated" date. We do not hold contact details for most of the people this policy concerns, so the published version is the notice.

Contact Us

• Appeals and rights requests: contact@rayward.app. This is the fastest route, and the one to use for anything about a flag on an account.
• Discord: our community Discord is linked from the site.
• Business inquiries: contact@rotector.com. We accept rights requests sent here and will respond, but the appeals address is faster for verification.