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The policy states that Robinhood does not knowingly collect personal information from users under 13, with an exception for children added as authorized users of credit card accounts by a parent or guardian who provides verifiable consent.
This analysis describes what Robinhood's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that children under 13 may have personal information collected by Robinhood in the context of credit card authorized user arrangements, subject to parental or guardian consent. This carve-out from the general prohibition on under-13 data collection engages COPPA requirements for verifiable parental consent and the Robinhood Children's Privacy Notice.
Interpretive note: The adequacy of a parental representation of consent versus COPPA's verifiable parental consent standard depends on the specific consent mechanism implemented, which is described in the Robinhood Children's Privacy Notice rather than this document.
The updated privacy policy reorganizes how Robinhood discloses its handling of financial information, now grouping GLBA-regulated disclosures by individual service entity with updated reference links rather than listing all entities in a single section. The policy also removed coverage of Robinhood Social, meaning privacy practices for that social media product are no longer described in this statement. The revised policy clarifies that it applies when you are logged into services or interact through online customer service channels, and directs users to a separate Robinhood Markets US Online Privacy Statement for information about non-financial data collection practices.
View change record →Under this provision, personal information about children under 13 may be collected by Robinhood when they are added as authorized credit card users by a parent or guardian who consents in accordance with the Robinhood Children's Privacy Notice. The agreement states that a parent or guardian representation of consent is required before such data collection proceeds.
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"With the exception of authorized users of our credit cards, we do not knowingly collect or solicit any information from anyone under the age of 13 through our Services. If we become aware that a child under 13 has provided us with personal information for any reason other than being added as an authorized user by their parent or guardian, we will take reasonable steps to delete that information. If you attempt to add an authorized user to your account who is under the age of 13, we will request that you represent that you are the parent or legal guardian of that individual and that you consent to our collection and use of the child's personal information in accordance with the Robinhood Children's Privacy Notice.Excerpt from Robinhood's Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The provision's reliance on a parental representation of consent rather than a verified consent mechanism may require evaluation against COPPA's verifiable parental consent standards. The Robinhood Children's Privacy Notice is referenced but not reproduced in this document. 2. GOVERNANCE EXPOSURE: Medium. The credit card authorized user carve-out for children under 13 is operationally significant because it creates a pathway for under-13 data collection that must be fully compliant with COPPA verifiable parental consent requirements. The adequacy of the consent mechanism should be confirmed against FTC COPPA guidance. 3. JURISDICTION FLAGS: COPPA applies federally to all operators collecting personal information from children under 13. Several states have enacted additional children's privacy protections, including California (Age-Appropriate Design Code), which may impose additional obligations beyond COPPA for platforms accessible to minors. 4. CONTRACT AND VENDOR IMPLICATIONS: Vendors who receive data relating to authorized credit card users under 13, including identity verification and credit card issuing partners, should be confirmed to have appropriate COPPA-compliant data handling practices in place. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the parental consent mechanism for adding authorized credit card users under 13 satisfies COPPA's verifiable parental consent requirements, that the Robinhood Children's Privacy Notice is current and accessible, and that data systems correctly classify under-13 authorized user data for appropriate handling and retention.
This provision establishes that children under 13 may have personal information collected by Robinhood in the context of credit card authorized user arrangements, subject to parental or guardian consent. This carve-out from the general prohibition on under-13 data collection engages COPPA requirements for verifiable parental consent and the Robinhood Children's Privacy Notice.
Under this provision, personal information about children under 13 may be collected by Robinhood when they are added as authorized credit card users by a parent or guardian who consents in accordance with the Robinhood Children's Privacy Notice. The agreement states that a parent or guardian representation of consent is required before such data collection proceeds.
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