Provisions index

The policy states that if a user does not provide personal information required by applicable law, including for AML and KYC compliance, BAM will close the user's account....

Why it matters: This provision establishes a direct operational consequence for non-compliance with information requests tied to legal obligations. For users holding cryptocurrency assets on the platform, account closure triggered by this provision would require resolution of any outstanding balances or positions....

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The policy authorizes BAM to create de-identified or anonymized datasets from user personal information and to disclose those datasets to third parties for the third parties' own independent purposes....

Why it matters: This provision permits disclosure of derived data to third parties without restriction on those third parties' use, provided the data meets BAM's de-identification standard. Compliance teams should evaluate whether the de-identification methodology meets applicable regulatory standards, including CCPA's de-identification requirements, given that re-identification of cryptocurrency transaction data may be technically feasible....

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The policy prohibits use of the Binance.US platform by individuals under 18 and states that BAM will delete personal information, close accounts, and restrict platform access upon notification that a user under 18 has provided personal information....

Why it matters: The policy establishes 18 as the minimum age for platform access and provides a mechanism for reporting underage users. Compliance teams should assess whether the platform's age verification procedures are adequate to prevent underage access given the sensitivity of financial and biometric data collected during onboarding....

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Users grant Public.com a broad, royalty-free, assignable, and sublicensable license to use any content they post, including for advertising and marketing purposes, across all media formats now known or later developed. The license also covers creating derivative works from user content and retransmitting it....

Why it matters: This provision authorizes Public.com to use, reproduce, distribute, and create derivative works from user-posted content for advertising and marketing purposes without additional compensation or user approval. The assignable and sublicensable nature of the license means these rights may be transferred to or exercised by third parties....

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Public.com's total liability to any user for all claims related to the Public Service is capped at the greater of the amount the user paid to Public.com in the prior 12 months or $100. This cap covers all claim types, including contract, tort, and statutory claims....

Why it matters: This provision establishes a maximum financial recovery ceiling for all claims against Public.com arising from use of the Public Service, regardless of the nature or magnitude of the underlying claim. The $100 floor means that users who have paid little or nothing to Public.com have a very low maximum recovery under these terms....

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Public.com reserves the right to terminate or suspend any user account at any time, for any reason or no reason, with or without notice, at its sole discretion. Violations of the Terms result in automatic termination of access....

Why it matters: This provision authorizes Public.com to terminate account access without advance notice or stated justification. For users with active brokerage accounts or open investment positions, abrupt platform access termination may affect their ability to manage those positions, though brokerage-specific terms are governed separately by the Public Brokerage Agreement....

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Public.com reserves the right to change the Terms of Service at any time with 7 days' advance notice. Immaterial modifications take effect upon publication, while material modifications require user acceptance before taking effect....

Why it matters: This provision establishes a 7-day notice period for changes to the Terms, which is shorter than the 30-day period more commonly observed in consumer financial services agreements. Immaterial changes become effective upon publication without any user action or acceptance....

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The policy requires that any AI output constituting a High-risk AI Recommendation in domains such as medical, legal, financial, credit, insurance, housing, employment, education, or public benefits must be reviewed and approved by a qualified human before it is acted upon or delivered to an individual....

Why it matters: This provision requires operators deploying Claude in high-stakes decision workflows to implement structured human review processes, including defined qualifications for reviewers and documented authority to override AI outputs, before any recommendation reaches an affected individual....

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The policy requires that any individual who receives advice or is subject to a decision produced using a High-risk AI Recommendation must be informed that AI was involved in generating it, though the specific AI system or provider does not need to be named....

Why it matters: This provision establishes a mandatory disclosure obligation that operators must implement at the point of delivery for any High-risk AI Recommendation, affecting consumer-facing product design and workflow documentation across twelve defined high-stakes domains....

View provision → Watch Anthropic →

The policy requires that any product using Claude to communicate directly with external users as a chatbot or AI agent must disclose the AI nature of the interaction at the start of each chat session or within the product interface....

Why it matters: This provision creates a mandatory per-session or persistent interface disclosure obligation for all operators deploying consumer-facing Claude-based chatbots or agents, requiring product design changes for any deployment that does not currently surface this disclosure....

View provision → Watch Anthropic →

The policy states that Anthropic will report to relevant authorities when it detects child sexual abuse material, activity facilitating CSAM, or scenarios indicating imminent risk of sexual abuse or exploitation of a minor, applying a uniform definition of minor as under 18 years old regardless of local age-of-majority laws....

Why it matters: This provision establishes that Anthropic's monitoring systems will generate mandatory reports to authorities upon detection of CSAM or related activity, and that the under-18 definition applies universally, which is relevant for operators in jurisdictions where age of majority differs....

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The policy prohibits using Claude to track or monitor individuals without their consent across physical location, biometrics, movements, online activities, communications, or associations, and explicitly names facial recognition, battlefield management, predictive policing, and law enforcement monitoring as prohibited applications....

Why it matters: This provision establishes categorical restrictions on surveillance-adjacent deployments, explicitly naming facial recognition and predictive policing as prohibited use cases, which directly limits operator deployments in law enforcement technology, national security, and commercial surveillance contexts....

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The policy requires that any hardware controlled by Claude outputs capable of high-risk physical actions must have a qualified human observer with the ability to stop the equipment at any time, automatic safe-state defaults upon connection loss, and safety limits enforced by hardware or a controller that operates independently of the AI model's output....

Why it matters: This provision requires operators connecting Claude to hardware capable of physical harm to implement hardware-level independent safety controls and continuous qualified human oversight, applying to robotics, autonomous vehicles, medical devices, industrial control systems, and other physical systems....

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The policy places full compliance responsibility on operators who build or deploy AI agents, covering all actions those agents take through connected tools, browsers, or systems, not just the instructions given to the agent....

Why it matters: This provision establishes that operator compliance obligations under the policy extend to the downstream actions of AI agents, including autonomous tool use and browser interactions, rather than being limited to direct model inputs or outputs....

View provision → Watch Anthropic →

The policy reserves Anthropic's right to negotiate modified use restrictions with governmental customers, applying a discretionary standard based on Anthropic's own judgment of whether contractual safeguards adequately mitigate the harms the standard policy addresses....

Why it matters: This provision creates a variable policy baseline for governmental customers, meaning that prohibitions stated in the Universal Usage Standards or other policy sections may not apply uniformly to government deployments where Anthropic has entered into a separate contract....

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The policy establishes that Anthropic monitors for Usage Policy violations and may warn, throttle, limit, suspend, or terminate account access upon suspected violations, while also noting that real-time output blocks do not constitute a violation determination....

Why it matters: This provision establishes Anthropic's enforcement authority and the range of account restrictions available upon suspected violations, including termination, and distinguishes between automated output blocks and formal violation determinations....

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The policy authorizes Meta to use publicly posted content, including posts, comments, and audio, as well as interactions with Meta AI features and third-party partner data, to develop and improve AI systems at Meta for use in both Meta Products and for third parties....

Why it matters: This provision establishes that user-generated public content serves as training data for AI model development, including for third-party applications, and applies to all users who post public content on any Meta Product. Compliance teams should evaluate whether this use is adequately disclosed and whether applicable law in relevant jurisdictions requires a distinct consent mechanism or opt-out for AI training uses....

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The policy states that Meta's systems automatically process stored user data to identify Meta Product users and serve personalized ads through the Meta Audience Network when those users visit third-party apps, using data including device identifiers, behavioral data, and network information....

Why it matters: This provision establishes that Meta's ad personalization infrastructure extends beyond Meta-owned platforms to third-party apps participating in Meta Audience Network, using data associated with users' Meta accounts to target ads in those external environments. The mechanism relies on cross-app identification using device identifiers, cookies, and behavioral data....

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The policy states that Meta receives behavioral and activity data about users from advertisers, businesses, and other partners regarding activity occurring outside Meta Products, and uses this off-platform data to personalize ads shown on Meta Products and affiliated advertising services, including for users who are not logged in or do not have a Meta account....

Why it matters: This provision establishes that Meta's ad personalization system incorporates data from external parties about users' off-platform activity, and that this data collection and association occurs regardless of whether the individual has a Meta account or is logged in. The mechanism for associating off-platform activity with non-account holders warrants evaluation under applicable privacy frameworks....

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The policy states that Meta transfers, stores, and processes user information globally including to and from the United States, sharing data internally across offices and data centers and externally with partners, third parties, and service providers, identifying global operations and service provision as the basis for these transfers....

Why it matters: This provision establishes that user data from all jurisdictions, including EU and UK users, is transferred to and processed in the United States and other countries. The legal mechanisms supporting these transfers, such as Standard Contractual Clauses or the EU-US Data Privacy Framework, are referenced in the full policy but not detailed in the extracted text, and compliance with applicable transfer requirements is a material consideration....

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The policy states that in the event Meta sells or transfers all or part of its business, user information may be transferred to the new owner as part of the transaction, subject to applicable law....

Why it matters: This provision establishes that user data may be transferred to a third-party acquirer in the event of a business sale, merger, or partial transfer, and that the new owner would receive user information under the terms of such a transaction. The constraint to what applicable law allows provides a legal guardrail but does not specify what user notice or consent would be provided....

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The policy states that when users connect to third-party integrated partners through Meta Products, those partners receive information about the user and their activity, and that integrated partners may always access publicly available information on Meta Products regardless of whether a user has explicitly connected with them....

Why it matters: This provision establishes that integrated partners have ongoing access to public profile and content data, and that users who connect to integrated partners share additional activity and profile information with those partners. The scope of information shared with integrated partners and how those partners handle it is governed by their own terms and policies rather than Meta's policy alone....

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Bank of America reserves the right to change, add, delete, or amend any account terms, fees, services, or conditions in this schedule at any time, and may also convert or discontinue existing accounts or services....

Why it matters: This provision establishes a broad contractual reservation of authority to modify fee structures, account terms, and available services without specifying a notice period or consumer consent requirement, though applicable law, including Regulation DD and state-specific deposit account statutes, may independently require advance notice for certain types of changes....

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Bank of America states that interest rates on variable-rate deposit accounts may be changed at the bank's discretion at any time, without a specified upper or lower limit and without advance notice to the account holder....

Why it matters: This provision asserts that the bank may adjust variable interest rates on deposit accounts without prior notice and without a stated floor or ceiling, which is a standard feature of variable-rate deposit products but may interact with Regulation DD change-in-terms disclosure requirements depending on how the rate change is characterized....

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The Advantage SafeBalance Banking for Family Banking account prohibits incoming transfers from non-Bank of America accounts, including ACH deposits, Zelle transfers, and employer direct deposits; the account agreement states that the account owner affirmatively authorizes Bank of America to treat such transfers as unauthorized and to reject them at the bank's discretion....

Why it matters: This provision establishes a structural restriction on incoming fund flows to the Family Banking account that is operationally distinct from standard personal checking accounts; the explicit characterization of external transfers as 'unauthorized' by the account owner's agreement may have implications under Regulation E, which governs consumer rights for unauthorized electronic fund transfers....

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BofA Rewards enrollment and tier benefits may be terminated or downgraded without further notice if, following an Annual Review, the account holder fails to meet qualifying checking account or minimum average balance requirements within a grace period of not less than three months....

Why it matters: This provision establishes that fee waivers, ATM fee refunds, overdraft fee waivers, and other BofA Rewards benefits linked to tier status may be discontinued or reduced immediately without additional notice at the conclusion of the grace period, affecting the ongoing operational cost structure for enrolled customers who rely on tier-based fee waivers....

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The agreement requires users and OpenAI to resolve all disputes through final and binding arbitration administered by NAM, covering claims regardless of when they arose. Users may opt out of arbitration by submitting a designated form within 30 days of account creation or within 30 days of any arbitration term update taking effect....

Why it matters: This provision establishes that disputes proceed through individual arbitration under NAM rules rather than through court litigation, with the Federal Arbitration Act governing enforcement. The 30-day opt-out window from account creation or from any arbitration update is the operative mechanism for users who wish to preserve court-based dispute resolution....

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The agreement limits OpenAI's aggregate liability to the greater of amounts paid by the user for the relevant service in the 12 months preceding the claim or $100. Indirect, incidental, special, consequential, and exemplary damages are excluded entirely....

Why it matters: This provision establishes a $100 floor on aggregate liability for free-tier users and a 12-month payment lookback cap for paid subscribers. The exclusion of consequential and data loss damages is operationally significant for users who may experience losses arising from reliance on AI-generated Output....

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The agreement assigns OpenAI's rights in generated Output to the user, while noting that Output may not be unique and similar Output may be generated for other users. The assignment does not extend to other users' output or Third Party Output....

Why it matters: This provision establishes a contractual assignment of Output ownership from OpenAI to users, qualified by the phrase 'to the extent permitted by applicable law' and by the acknowledgment that Output may not be unique. The practical scope of intellectual property rights in AI-generated content remains an evolving area of law in multiple jurisdictions....

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Accounts created using organizational email addresses may be transferred to the organization's business account, after which the organization's administrator gains control over the account including access to Content and the ability to restrict or remove user access. OpenAI states it will provide notice to the user prior to transfer unless the organization has already done so....

Why it matters: This provision establishes that organizational email-based accounts are subject to potential employer or organizational administrator control, including access to user-generated Content. The notice obligation is qualified by the carve-out for situations where the organization has already notified the user....

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The agreement requires users to evaluate Output for accuracy before use, prohibits reliance on Output as a sole factual source or substitute for professional advice, and expressly prohibits use of Output about a person for decisions with legal or material impact including credit, employment, housing, insurance, legal, and medical decisions....

Why it matters: This provision establishes affirmative user obligations regarding Output evaluation and creates an express prohibition on high-stakes decisional use of Output concerning individuals. These obligations are operationally significant for any enterprise or professional deploying AI-generated content in decision-making workflows....

View provision → Watch OpenAI →

The agreement reserves OpenAI's right to suspend, terminate, or delete accounts for Terms or Usage Policy violations, legal compliance reasons, risk or harm determinations, or inactivity exceeding one year for unpaid accounts. An appeal mechanism is available through the Support team....

Why it matters: This provision establishes the grounds and process for account termination, including a broad risk or harm standard that is not further defined. The inactivity termination provision applies specifically to free accounts inactive for more than one year, with advance notice stated as a condition....

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The document authorizes Robinhood to use user data including AI chatbot conversation inputs to train, test, and improve its AI functionalities, and states that notice and consent will be obtained where required by applicable law....

Why it matters: This provision authorizes secondary use of user conversation data for AI model development, which may engage state AI transparency laws and FTC guidance on AI data practices. The phrase 'where required under applicable law' conditions consent obligations on regulatory requirements, meaning the scope of user consent is jurisdiction-dependent....

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The document states that personal information collected in connection with financial services (such as a brokerage account) is generally governed by GLBA rather than state privacy laws such as the CCPA, and that Robinhood may have no obligation to accept or honor Data Subject Requests depending on which affiliate and product the user's data relates to....

Why it matters: This provision describes the scope of GLBA preemption as Robinhood applies it across its product lines, establishing that the availability of state-law privacy rights including access, deletion, and correction requests depends on which Robinhood entity and product a user interacts with. The practical scope of GLBA preemption is a fact-specific and legally contested question, and compliance teams should not assume the document's characterization reflects the full extent of applicable legal obligations....

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The document authorizes Robinhood to share user personal information including name, address, telephone number, and social security number with affiliated Robinhood entities for purposes including service delivery and cross-product applications, and states that users may limit this sharing in some cases through GLBA opt-out mechanisms....

Why it matters: This provision establishes that social security numbers and other identity data may be shared across Robinhood's affiliated entities as part of standard operations. The document provides a limited opt-out mechanism through the GLBA financial privacy notices, though the scope of what can be limited is constrained by GLBA's permitted sharing categories....

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The document authorizes Robinhood and third-party advertising and analytics partners to collect device identifiers, IP addresses, browsing activity, and conversion information through cookies, pixels, and SDKs, and to use this data for cross-platform targeted advertising, with opt-out controls available through account settings and industry opt-out tools....

Why it matters: This provision establishes that behavioral advertising data sharing with third-party partners applies by default, and that data collected through these technologies may be combined across devices and websites over time. Users must affirmatively opt out through account settings or external tools such as the Digital Advertising Alliance opt-out at www.aboutads.info/choices....

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The document states that Robinhood retains personal information for up to 5 years after the end of the user relationship for regulatory compliance purposes, and may retain data for longer periods if required by law, in connection with ongoing or potential claims, or for other legitimate regulatory reasons....

Why it matters: This provision establishes a base retention period of up to 5 years post-relationship for personal information held by Robinhood's financial entities, reflecting regulatory recordkeeping obligations applicable to broker-dealers and money services businesses. The open-ended extension for legal claims or regulatory reasons means the maximum retention period is not fixed....

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The document states that Social profile information including username, profile statistics (which may include profit and loss metrics), posts, and follower data is visible to other Robinhood users by default, and that content may be shared outside the Social product to external social media platforms....

Why it matters: This provision establishes that financial performance metrics such as profit and loss ratios may be displayed on user Social profiles and shared with other users, including potentially outside the Robinhood platform. Deactivation hides the profile from other users but does not delete data; full deletion requires a separate action....

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The document states that the Pay and Request profile, including profile picture, username, full name, join year, and transaction history between users, is visible to all Robinhood users by default, and that users may opt out of this visibility at any time through profile visibility settings....

Why it matters: This provision establishes that transaction history between users is visible by default to the counterparty and potentially to other Robinhood users depending on settings, and that opting out requires affirmative adjustment of profile visibility settings....

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The document states that Robinhood may disclose user personal information to third parties in connection with mergers, acquisitions, financing transactions, changes in control, or bankruptcy proceedings....

Why it matters: This provision permits transfer of personal information to acquiring or successor entities without requiring individual user consent, which is standard in corporate transaction contexts but means user data may be processed by a different entity following a transaction....

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The agreement authorizes Robinhood to recover amounts owed by debiting the customer's brokerage account, external bank accounts, any affiliated Robinhood accounts, and any account in which the customer holds a beneficial interest, without prior notice. This authorization survives account termination....

Why it matters: This provision establishes a cross-entity, post-termination right of offset that extends beyond the brokerage account to external bank accounts and accounts in which the customer holds only a beneficial interest. The scope of this offset authorization may require evaluation under applicable state offset, garnishment, and exemption statutes, as well as Regulation E protections for consumer deposit accounts....

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The agreement states that unauthorized third-party access to the account, device, username, or password is solely the customer's risk. Any instruction or order given for the account, including via the platform using the account username or password, is treated as authorized by the customer regardless of who placed it....

Why it matters: This provision places full risk of unauthorized access on the customer if someone else obtains account credentials, and treats all orders placed using account credentials as authorized. The allocation of responsibility for unauthorized access interacts with FINRA investor protection rules and applicable consumer protection law, which may impose obligations on the broker-dealer that are not fully captured by this contractual allocation....

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When Coinbase batches multiple user transactions together, the total estimated network fees collected from those users may exceed the actual network fee Coinbase pays, with the document disclosing but not specifying disposition of the difference....

Why it matters: This provision discloses that Coinbase may collect more in estimated network fees from a group of users than it ultimately pays to the network when batching transactions. The practical financial differential between fees collected and fees paid is not explicitly addressed in terms of return or credit to users....

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Coinbase charges no upfront staking fee but retains a commission of 25.25% to 35% of all staking rewards received from the network, depending on the asset and the user's Coinbase One membership tier....

Why it matters: This provision establishes the rate at which Coinbase extracts commission from user staking rewards across eight named cryptocurrency assets. The commission is applied to gross network rewards before the user receives their share, meaning the APY and rewards displayed in the account reflect post-commission earnings....

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Coinbase charges a 1% limit order execution fee on each limit buy and limit sell order, which may apply in addition to a separate Coinbase fee of up to 1.875% depending on payment method....

Why it matters: This provision establishes that limit orders carry a mandatory 1% execution fee that is separate from and additive to the standard Coinbase fee, meaning limit order users may pay up to approximately 2.875% in combined fees on a single transaction before spread is applied. The document also states this 1% fee is excluded from Coinbase One zero-fee trading benefits....

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DEX trades via Coinbase's DEX Trading feature incur an additional service fee on top of the standard Coinbase fee, Coinbase may retain any excess service fee, the final execution price may differ from the quoted estimate, and these fees and price variations are excluded from Coinbase One zero-fee benefits....

Why it matters: This provision establishes that DEX trading carries an additive fee structure with an undetermined service fee amount, price execution uncertainty capped only by a disclosed slippage tolerance, and explicit exclusion from subscription fee waivers. DEX aggregators routing the trade may also retain any price improvement over the quoted price as a fee....

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When Coinbase or an affiliate sells a borrower's BTC collateral pursuant to a loan agreement, Coinbase charges a flat 2% fee on the total liquidation transaction amount....

Why it matters: This provision establishes a 2% liquidation fee applied to collateral sales under Coinbase lending arrangements. The fee applies to the total transaction amount, meaning it is charged on the gross value of the BTC sold rather than on any margin or differential....

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Coinbase charges a network fee for all asset recovery attempts on unsupported cryptocurrencies, plus a 5% recovery fee on the portion of estimated recovery value exceeding $100, with a noted caveat that the estimated value used to calculate the fee may differ from the actual recovered value....

Why it matters: This provision establishes that asset recovery for unsupported cryptocurrencies is a fee-bearing service with two cost components: a network fee and a 5% fee on estimated value above $100. The acknowledgment that estimated value may differ from actual market value at recovery means users may pay a fee calculated on a basis that does not reflect the ultimate value received....

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Coinbase charges a 0.10% processing fee on net USDC conversion amounts exceeding $5 million in a 30-day rolling period, with net volume calculated by offsetting USDC-to-USD or USDC-to-PYUSD conversions against USD-to-USDC or PYUSD-to-USDC conversions....

Why it matters: This provision establishes a threshold-based fee structure for high-volume USDC converters that applies a netting methodology to determine taxable volume. The 30-day rolling calculation window and netting approach create operational tracking requirements for institutional or high-volume users managing large USDC positions....

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Coinbase charges a fee for instant unstaking or for converting a pending standard unstake to an instant unstake, with the specific fee amount disclosed at the time of the unstaking request rather than in advance in this document....

Why it matters: This provision establishes that users who wish to access staked assets immediately rather than waiting for the standard unbonding period will pay a fee disclosed only at the time of the request. The fee amount is not specified in the fee schedule itself, meaning users cannot assess the cost before initiating the unstaking process....

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