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The policy authorizes disclosure of user personal information including name, address, telephone number, and social security number to other Robinhood-affiliated entities for purposes including credit card applications and custody services.
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 intra-group data sharing across Robinhood's affiliated entities, including disclosure of social security numbers. The GLBA financial privacy notices provide an opt-out mechanism for certain affiliate data sharing, and the policy directs users to those notices and to privacy@robinhood.com to exercise that right.
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 including social security numbers may be shared among Robinhood-affiliated entities such as Robinhood Credit, Inc. and Robinhood Securities, LLC for purposes including credit card applications. The agreement states users can limit some affiliate sharing by reviewing GLBA financial privacy notices and contacting privacy@robinhood.com.
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"Robinhood affiliates : Where appropriate, we disclose information about you to other companies owned or controlled by Robinhood Markets. For example, if you are a Robinhood Financial customer, we may disclose information about you to Robinhood Securities, LLC to provide you with custody and other related services, as described in your customer agreement, or to Robinhood Credit, Inc. to facilitate your completion of an application for a credit card. This information could include, but is not limited to, your name, address, telephone number, and/or social security number. These companies will process any information disclosed to them in the same manner as described in this Privacy Statement.Excerpt from Robinhood's Privacy Policy
1. REGULATORY LANDSCAPE: Affiliate data sharing in financial services is governed by the GLBA affiliate sharing provisions, which require disclosure and in certain circumstances an opt-out opportunity. The FTC enforces GLBA compliance for non-bank financial institutions. CCPA Section 1798.125 and similar state statutes may also apply to non-GLBA-covered affiliate sharing, particularly for Robinhood Social-related data. 2. GOVERNANCE EXPOSURE: Medium. The disclosure that social security numbers may be shared across affiliates for credit card application purposes is consistent with standard financial services practice but requires clear documentation of the legal basis and opt-out mechanism. The policy's statement that shared information will be processed in the same manner as described in the Privacy Statement requires that all affiliates have consistent data handling practices. 3. JURISDICTION FLAGS: California CCPA affiliate sharing opt-out rights may apply to non-GLBA-covered data shared among affiliates. States with enacted comprehensive privacy laws may similarly require opt-out mechanisms for affiliate data sharing that falls outside GLBA coverage. 4. CONTRACT AND VENDOR IMPLICATIONS: Intra-group data sharing agreements should confirm that affiliated entities receiving personal information including social security numbers maintain data security standards consistent with GLBA Safeguards Rule requirements and applicable state law. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that affiliate sharing opt-out mechanisms described in GLBA notices are functional and adequately disclosed, that data sharing among affiliates is documented in data flow maps, and that the Privacy Statement's representation that all affiliates process data in the same manner is operationally accurate across the full affiliate group.
This provision establishes intra-group data sharing across Robinhood's affiliated entities, including disclosure of social security numbers. The GLBA financial privacy notices provide an opt-out mechanism for certain affiliate data sharing, and the policy directs users to those notices and to privacy@robinhood.com to exercise that right.
Under this provision, personal information including social security numbers may be shared among Robinhood-affiliated entities such as Robinhood Credit, Inc. and Robinhood Securities, LLC for purposes including credit card applications. The agreement states users can limit some affiliate sharing by reviewing GLBA financial privacy notices and contacting privacy@robinhood.com.
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