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The policy authorizes sharing of hashed email addresses, device identifiers, and online activity information from Robinhood Social users with advertising and analytics partners for cross-context behavioral advertising, subject to user data sharing preferences.
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 Robinhood Social constitutes a context in which user identifiers and activity data may be shared for behavioral advertising purposes. The CCPA and similar state statutes treat cross-context behavioral advertising data sharing as a sale or sharing of personal information subject to opt-out rights, and the policy provides an in-app opt-out mechanism for this purpose.
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, users of Robinhood Social who have not adjusted their data sharing preferences may have identifiers and online activity data shared with advertising and analytics partners for cross-context behavioral advertising. The agreement provides an opt-out mechanism accessible in-app through Account, then Security and Privacy, then Manage your data, then Your privacy choices.
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"For Advertising and Analytics We may share certain identifiers (such as hashed email address or device identifiers) and online activity information with advertising and analytics partners to support cross-context behavioral advertising and measurement, subject to applicable law and your data sharing preferences, as described in Disclosures of Information and Third-Party Tracking and Online Advertising above.Excerpt from Robinhood's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages the CCPA definition of sale and sharing of personal information, enforced by the California Privacy Protection Agency. The Global Privacy Control (GPC) may also be implicated as a recognized opt-out signal under CCPA regulations. Similar opt-out rights exist under Virginia VCDPA, Colorado CPA, Texas TDPSA, and other state privacy statutes. The provision acknowledges that some Social business activities may be considered sales, sharing, or targeted advertising under applicable US state laws. 2. GOVERNANCE EXPOSURE: Medium. The provision is substantively consistent with CCPA-compliant cross-context behavioral advertising disclosure and opt-out practices. Compliance exposure centers on whether the GPC is honored as an opt-out signal, whether the opt-out mechanism is sufficiently accessible and effective, and whether the advertising partner list is adequately disclosed. 3. JURISDICTION FLAGS: California creates heightened exposure due to CPPA enforcement of CCPA opt-out and GPC requirements. States with enacted comprehensive privacy laws (Virginia, Colorado, Texas, Connecticut) impose analogous opt-out obligations for targeted advertising data sharing. 4. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with advertising and analytics partners receiving hashed email addresses and device identifiers should confirm restrictions on secondary use, consistent with CCPA service provider or contractor requirements if applicable, or acknowledge the sharing constitutes a sale or share with opt-out rights as described. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm the GPC signal is recognized and honored by Robinhood Social's data systems, verify that the opt-out mechanism described in the policy is fully functional and applies to all downstream advertising partners, and ensure advertising partner contracts are classified correctly under CCPA as either service providers or third parties receiving data through a sale or share.
This provision establishes that Robinhood Social constitutes a context in which user identifiers and activity data may be shared for behavioral advertising purposes. The CCPA and similar state statutes treat cross-context behavioral advertising data sharing as a sale or sharing of personal information subject to opt-out rights, and the policy provides an in-app opt-out mechanism for this purpose.
Under this provision, users of Robinhood Social who have not adjusted their data sharing preferences may have identifiers and online activity data shared with advertising and analytics partners for cross-context behavioral advertising. The agreement provides an opt-out mechanism accessible in-app through Account, then Security and Privacy, then Manage your data, then Your privacy choices.
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