Acorns Privacy Policy

This document is Acorns' consumer-facing privacy policy governing the collection, use, sharing, and retention of personal information across Acorns' suite of financial products, including brokerage accounts, IRAs, banking, and the Acorns Early custodial investment and debit card products. The policy states that Acorns collects a broad range of personal data including government-issued identification, Social Security numbers, financial account credentials, transaction history, device identifiers, geolocation data, and behavioral/usage data, and the terms authorize sharing this information with affiliated companies, service providers, marketing partners, and third parties for purposes including targeted advertising and analytics. Notably, the policy asserts the right to collect data from third-party sources such as data brokers and social media platforms to supplement user profiles, and it reserves the right to share personal information in connection with business transfers such as mergers or acquisitions, which is standard in the industry but operationally significant given Acorns' multi-product financial data footprint. As a registered investment adviser and broker-dealer operating banking, brokerage, and custodial products for minors, Acorns' data practices engage the Gramm-Leach-Bliley Act, the California Consumer Privacy Act as amended by CPRA, COPPA with respect to the Early product, and FTC Act consumer protection standards, with the CFPB and SEC also holding relevant supervisory authority over aspects of Acorns' regulated activities. California residents and users of the Acorns Early minor-facing product face distinct and heightened legal protections that the policy acknowledges, though compliance teams should evaluate whether disclosures and consent mechanisms fully satisfy applicable statutory requirements across all product lines.