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Webull reserves the right to revise the privacy policy at any time, and states that even material changes will be communicated only by updating the document on its website or app, without sending a separate notification to users. Continued use of the services after changes take effect constitutes agreement to the revised policy.
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
This provision establishes that users are bound by revised policy terms through continued use of the services, without requiring affirmative acknowledgment or direct notification, even when the company determines a change is material. This mechanism may require evaluation under GDPR transparency and consent requirements and applicable state privacy law standards that mandate meaningful notice of material changes.
Interpretive note: Whether posting without direct notification satisfies transparency obligations under GDPR or applicable state law depends on jurisdiction-specific enforcement standards and the materiality of the specific changes made.
Under this clause, changes to the privacy policy, including material changes as determined solely by Webull, become binding upon continued use of the services after posting, without a separate notification being sent to users. Users are responsible for periodically checking the policy on the Webull website or app to identify any revisions.
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"We may revise this Policy from time to time. The most current version of the Policy will govern our use of your information. If we make any change to this Policy that, in our sole discretion, is material, we will update the Policy on our website or our app without a separate notification sent to you. Please refer to the most updated version of this Policy on our Webull app or our website. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Policy.Excerpt from Webull's Privacy Policy
1. REGULATORY LANDSCAPE: This provision may engage GDPR Articles 13 and 14, which require that data subjects be informed of changes to data processing in a transparent and timely manner. The FTC Act's prohibition on unfair or deceptive practices may also be relevant if material changes to data practices occur without adequate notice. State-level consumer protection statutes, including California's Consumers Legal Remedies Act, may impose additional notice requirements. 2. GOVERNANCE EXPOSURE: Medium. The provision's reliance on posting as the sole notice mechanism for material changes, combined with continued-use-as-acceptance, is a common industry practice but may face regulatory scrutiny in jurisdictions requiring affirmative or direct notification of material privacy practice changes, particularly where consent-based processing is involved. 3. JURISDICTION FLAGS: EEA and UK residents face heightened exposure, as GDPR imposes specific transparency obligations that may require more than passive website posting for material changes to data processing activities. California regulators have signaled increasing scrutiny of implied-consent mechanisms in privacy policy updates. 4. CONTRACT AND VENDOR IMPLICATIONS: B2B partners and institutional clients whose data processing relationships with Webull are governed in part by this policy should assess whether this unilateral update mechanism is compatible with their own contractual obligations to data subjects or regulators. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the current notice mechanism satisfies applicable legal requirements in each jurisdiction where Webull operates, and consider implementing a direct notification process, such as email notice, for material changes to data processing activities involving sensitive financial or identity data.
This provision establishes that users are bound by revised policy terms through continued use of the services, without requiring affirmative acknowledgment or direct notification, even when the company determines a change is material. This mechanism may require evaluation under GDPR transparency and consent requirements and applicable state privacy law standards that mandate meaningful notice of material changes.
Under this clause, changes to the privacy policy, including material changes as determined solely by Webull, become binding upon continued use of the services after posting, without a separate notification being sent to users. Users are responsible for periodically checking the policy on the Webull website or app to identify any revisions.
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