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The policy states that a user's Pay and Request profile, including profile picture, username, full name, join year, and bilateral transaction history, is visible by default to all Robinhood users unless profile visibility settings are adjusted.
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 Pay and Request profile information including transaction history between users is disclosed to other Robinhood users by default. The document states this default can be changed through profile visibility settings, and users may opt out of Pay and Request profile visibility at any time.
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, a user's Pay and Request profile including full name, profile photo, and bilateral transaction history with any viewing user is visible to all Robinhood users by default. The agreement states users may opt out of this visibility at any time through profile visibility settings.
Cross-platform context
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"With other users of our Services : We may disclose information about you with other users of our Services, such as our Pay & Request Service, for which you may not have yet enrolled. In such cases, we will disclose your Pay & Request profile which includes: your profile picture, username, full name, the year you joined, and the transaction history between you and the person viewing it, with other Robinhood users. For payments and requests, this helps others know they're getting money from you (or that you requested a payment from them). Your Pay & Request profile will be visible to anyone on Robinhood unless you adjust your profile visibility settings.Excerpt from Robinhood's Privacy Policy
1. REGULATORY LANDSCAPE: Default public visibility of financial transaction history between users engages FTC unfair or deceptive practices authority and state financial privacy laws. Where the disclosed information constitutes personally identifiable financial information under GLBA, disclosure to third-party users may require examination of whether this falls within GLBA's permitted disclosure framework. State privacy laws including CCPA may also apply to the disclosure of personal information to other users through the platform. 2. GOVERNANCE EXPOSURE: Medium. The default-visible configuration for profile and transaction history information creates compliance exposure if users are not clearly informed of the default at account setup or at first use of the Pay and Request feature. The policy notes that users may not have yet enrolled in Pay and Request at the time their profile becomes visible, which is a notable disclosure. 3. JURISDICTION FLAGS: California and other states with comprehensive privacy laws may require affirmative disclosure of default-sharing configurations and may impose obligations to honor opt-out requests promptly. The disclosure that transaction history between users is visible by default may also attract scrutiny under financial privacy frameworks. 4. CONTRACT AND VENDOR IMPLICATIONS: No direct vendor implications from this provision, as it governs user-to-user data visibility rather than third-party data sharing. However, the platform infrastructure supporting profile visibility and opt-out should be reviewed to confirm opt-out requests are processed in real time or near-real time. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the default-visible Pay and Request profile configuration is disclosed at the point of account creation or feature enrollment, that the opt-out mechanism is clearly accessible and functional, and that the transaction history visibility feature is consistent with applicable financial privacy requirements.
This provision establishes that Pay and Request profile information including transaction history between users is disclosed to other Robinhood users by default. The document states this default can be changed through profile visibility settings, and users may opt out of Pay and Request profile visibility at any time.
Under this provision, a user's Pay and Request profile including full name, profile photo, and bilateral transaction history with any viewing user is visible to all Robinhood users by default. The agreement states users may opt out of this visibility at any time through profile visibility settings.
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