The terms prohibit disclosure of user personal information except in six defined circumstances, the last of which (Section 4.6) permits disclosure whenever Webull unilaterally determines it to be necessary, without specifying the nature or category of such necessity.
This analysis describes what Webull'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
Section 4.6 creates an open-ended disclosure authorization that is not bounded by a legal basis, regulatory requirement, or defined category of necessity. This provision may require evaluation under the CCPA's requirements for disclosing personal information and GDPR's lawful basis requirements for data processing and transfer.
Interpretive note: The practical scope of Section 4.6 depends on how Webull defines 'necessary' in practice and whether applicable state or international privacy laws constrain its application; the Privacy Policy may provide additional specificity not present in this document.
This added provision creates a privacy promise with broad exceptions that permit disclosure for multiple scenarios beyond legal requirements, potentially allowing wide sharing of personal data.
View full change record →Under this clause, Webull may disclose a user's personal information, including information collected during registration and platform use, in any circumstance Webull determines to be necessary, in addition to the five enumerated categories. The Webull Privacy Policy is referenced for additional detail but this Terms of Service document does not further define the scope of Section 4.6.
Cross-platform context
See how other platforms handle Discretionary User Data Disclosure and similar clauses.
Compare across platforms →"Webull promises not to disclose any personal or other information provided to Webull in confidence, including information provided during the account registration process or collected by Webull while the user was using the Products, except for the following situations: 4.1 disclosure is required by relevant laws and regulations; 4.2 disclosure is required by a third-party to complete a transaction initiated by the user; 4.3 situations related to the protection of Webull's intellectual property rights or other important rights; 4.4 the username or password is illegally used as a result of hacking or negligence by the user; 4.5 emergency situations in which public privacy and security are at risk; and 4.6 other situations in which Webull determines such disclosure is necessary.Excerpt from Webull's Customer Agreement
1) REGULATORY LANDSCAPE: This provision implicates the California Consumer Privacy Act (CCPA) and its amendment under the CPRA, which require specific disclosure of the categories of personal information shared and the purposes for sharing.
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Section 4.6 creates an open-ended disclosure authorization that is not bounded by a legal basis, regulatory requirement, or defined category of necessity. This provision may require evaluation under the CCPA's requirements for disclosing personal information and GDPR's lawful basis requirements for data processing and transfer.
Under this clause, Webull may disclose a user's personal information, including information collected during registration and platform use, in any circumstance Webull determines to be necessary, in addition to the five enumerated categories. The Webull Privacy Policy is referenced for additional detail but this Terms of Service document does not further define the scope of Section 4.6.
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