Provisions index

The policy states that Binance.US does not sell personal information to advertising providers for monetary consideration, but acknowledges that data disclosures to advertising service providers may qualify as a 'sale' or 'share' under applicable state privacy laws. Users in applicable states can opt out through the Online Tracking Opt-Out Guide....

Why it matters: This provision establishes that advertising-related data transfers are occurring and that the company acknowledges they may trigger opt-out rights under state privacy statutes including CCPA, even while asserting no monetary sale occurs. Compliance teams should confirm that opt-out mechanisms are fully functional and that advertising partners are contractually restricted from independent use of the data....

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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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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 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 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 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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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 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 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 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 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 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 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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When Coinbase batches multiple user transactions together, the total of estimated network fees collected from individual users may be greater than the actual network fee Coinbase pays, with Coinbase retaining the difference....

Why it matters: This provision discloses that Coinbase may collect more in estimated network fees from users than it ultimately remits to the network due to batching efficiencies, establishing a fee retention mechanism that operates separately from stated trading fees and spreads. The operational significance of this provision lies in its potential to create a gap between disclosed fee estimates and actual user costs relative to Coinbase's network expenditure....

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Limit buy and limit sell orders incur a 1% execution fee on the trade amount, in addition to a Coinbase fee of up to 1.875% depending on payment method, with both fees disclosed in the order preview screen and transaction history....

Why it matters: This provision establishes that limit orders carry a cumulative fee structure of up to approximately 2.875% per trade before any spread, which is distinct from the fee structure applicable to simple market orders. The document also states that the 1% limit order fee is not waived by Coinbase One zero-fee trading benefits, creating an operationally significant limitation for subscribers relying on that benefit....

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When Coinbase or an affiliate sells a user's Bitcoin collateral under the terms of an applicable loan agreement, a flat 2% fee on the total transaction value is charged....

Why it matters: This provision discloses a 2% liquidation fee on BTC collateral sales, which applies at the time of collateral liquidation rather than at origination of the loan. The fee is charged on the total transaction value, meaning it applies to the full sale amount rather than only to a net or excess amount....

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Coinbase charges a network fee for any unsupported cryptocurrency recovery attempt, plus a 5% fee on the estimated value exceeding $100 for eligible recoveries, with a disclaimer that the estimated value used for fee calculation may differ from actual market value at the time of recovery....

Why it matters: This provision establishes a 5% fee on estimated recovery value above $100, applied to a value figure that the document acknowledges may differ from actual market value. This creates a potential discrepancy between the fee basis (estimated value) and the value the user actually receives (market value), which may be material in volatile market conditions....

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The document states that all fees and charges are subject to change without specifying a notice period, notification mechanism, or effective date process for fee changes....

Why it matters: This provision reserves Coinbase's right to modify any fee or charge described in the schedule without specifying a required advance notice period or user notification procedure. The absence of a defined change notice mechanism creates uncertainty about when users will be informed of fee changes relative to when those changes take effect....

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The agreement authorizes Coinbase to hold user digital assets in shared omnibus blockchain addresses across multiple protocols, including layer two networks, alternative layer one networks, and side chains, and to treat different forms of the same asset held across these protocols as interchangeable regardless of wrapping status or the specific protocol on which they are stored....

Why it matters: This provision establishes that Coinbase is not required to maintain segregated blockchain addresses for individual user assets and may commingle holdings across multiple protocols with assets treated as fungible equivalents. This structure has implications for user asset tracing, insolvency risk assessment, and the practical ability to verify on-chain holdings independently....

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The agreement requires users to provide name, address, telephone number, email address, date of birth, taxpayer identification number, government identification, bank account information, and in some cases biometric data, for identity verification, AML and fraud detection, and ongoing compliance purposes. Coinbase may also authorize a user's wireless carrier to disclose device and account information to Coinbase for identity verification and fraud prevention....

Why it matters: This provision establishes the categories of personal and financial data Coinbase collects at account registration and on an ongoing basis, including the potential collection of biometric information where permitted by law. The provision also discloses that personal data may be shared with credit reference agencies, fraud prevention agencies, and financial crime agencies in connection with identity verification inquiries....

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When users share any content through Coinbase Services, including text, images, video, graphics, audio, files, and communications, the agreement authorizes Coinbase to use, modify, distribute, sublicense, and transfer that content on a worldwide, royalty-free, perpetual basis to operate, improve, develop, and promote its services....

Why it matters: This provision asserts a perpetual, sublicensable, and transferable license to user-generated content including communications, which means content shared through Coinbase Services may be used, modified, and redistributed by Coinbase and its sublicensees without time limitation and without additional compensation to the user....

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The agreement authorizes Coinbase to adjust its pricing and fees at any time, with a 30-day advance notice obligation limited to states where such notice is required by applicable law. Fees include both explicit transaction fees and a spread, which is a margin over the prevailing market rate that is not separately disclosed in transaction history records....

Why it matters: This provision establishes that the fee modification notice obligation is jurisdiction-dependent rather than a universal user protection, meaning users in states without statutory advance notice requirements may not receive prior notification of fee changes. The agreement separately discloses that transaction history records exclude spread or margin from the fee line items displayed....

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X reserves the right to suspend or terminate accounts for violation of terms, legal risk, unlawful conduct, prolonged inactivity, or commercial inviability, and also retains the right to terminate for any other reason or no reason at its convenience, to the extent permitted by law. Notification will be made by reasonable efforts via email or upon next account access....

Why it matters: This provision authorizes account termination on five enumerated grounds as well as for any reason or no reason at X's convenience, subject to applicable law. The commercial inviability ground and the convenience termination right are operationally significant for users, creators, and businesses that depend on platform access....

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X's total aggregate liability to any user is capped at the greater of $100 USD or the amount the user paid X in the prior six months for the specific services at issue. This cap applies across all theories of liability including contract, tort, statute, and warranty....

Why it matters: This provision establishes a maximum aggregate financial exposure for X of $100 USD (or six months of payments, if greater) regardless of the nature or severity of the claim. The cap applies across all legal theories and explicitly survives even if a remedy is found to have failed its essential purpose....

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X reserves the right to access, read, preserve, and disclose user information when it reasonably believes it is necessary to comply with legal processes, enforce its terms, address fraud or security issues, respond to support requests, or protect X, its users, or the public. Disclosure of personally identifying information to third parties is stated to occur only in accordance with the Privacy Policy....

Why it matters: This provision authorizes X to access and disclose user information including content and communications across five enumerated grounds, with disclosure to third parties (other than personally identifying information) not expressly limited to the Privacy Policy. The breadth of the reservation covers governmental requests, enforcement investigations, and safety determinations....

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X requires users to be at least 13 years old and permits adults to accept the Terms on behalf of a minor, thereby binding the minor to the Terms. Use of the Services constitutes acceptance of the Terms....

Why it matters: This provision establishes the minimum age of 13 and creates a mechanism for adult authorization of minor accounts, with the adult warranting authority to bind the minor. The 13-year minimum age threshold engages COPPA in the US and GDPR age of digital consent provisions in the EU....

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Users grant Microsoft a worldwide, royalty-free intellectual property license to use, copy, retain, transmit, reformat, display, and distribute their content through the services for the purposes of service provision, user protection, and improvement of Microsoft products and services. Content published in broadly accessible areas of the service may be used in promotional or demonstration materials....

Why it matters: This provision establishes a broad royalty-free license grant covering content uploaded, stored, or shared across all covered Microsoft consumer services. The license scope includes reformatting, reproduction, transmission, and distribution, and the agreement states that broadly published content may appear in promotional materials, which creates an operational consideration for users who share content in publicly accessible service areas....

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Microsoft reserves the right to modify the agreement at any time with notice to users; continued use of the services after changes take effect constitutes acceptance of the updated terms. Users who do not agree to changes must stop using all covered services and close their Microsoft accounts....

Why it matters: This provision establishes the mechanism by which Microsoft may update the contractual terms governing all covered services, with continued service use treated as acceptance of updated terms. The practical consequence is that material changes to data use, content licensing, arbitration, or other provisions become binding on active users who continue using the services after the effective date....

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Upon account closure by either the user or Microsoft, access to services stops immediately, and Microsoft will delete or disassociate data and user content from the account unless law requires retention or transfer. Microsoft states it cannot retrieve content or data once the account is closed, and users may lose access to previously acquired products....

Why it matters: This provision governs what occurs to user data and purchased content upon account closure, whether voluntary or initiated by Microsoft as an enforcement action. The provision establishes that data deletion is the default outcome, acquired product access may be permanently lost, and Microsoft disclaims the ability to recover data after closure....

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Subscription purchases authorize recurring payments at the agreed interval until the subscription is terminated; users must cancel before the next billing date to avoid further charges. The agreement also states that initiating a chargeback or payment reversal is treated as cancellation from the date of the original payment, and Microsoft may immediately cancel service and revoke provided content....

Why it matters: This provision establishes the auto-renewal mechanism for all subscription services covered by the agreement, requires pre-billing cancellation to stop charges, and treats chargebacks as retroactive cancellation events that trigger immediate service termination and content revocation....

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The schedule discloses that when Coinbase batches multiple user transactions together, the total estimated network fees charged to users in that batch may be higher than the actual network fee Coinbase ultimately pays, with Coinbase potentially retaining the difference....

Why it matters: This provision establishes a condition under which Coinbase may collect more in estimated network fees from users than it disburses to the network, with any differential retained by Coinbase. Compliance teams should evaluate whether this practice and its disclosure meet applicable consumer financial protection and fee transparency standards....

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When users execute trades through Coinbase's DEX Trading feature, third-party DEX aggregators routing those trades may retain any price improvement above the quoted price as their own fee, meaning the user does not receive the benefit of a better execution price than quoted....

Why it matters: This provision establishes that a third-party fee in the form of retained price improvement may apply to DEX trades without a disclosed fixed amount or percentage, in addition to the standard Coinbase fee and DEX service fee. The operational significance is that users cannot determine the size of this third-party retention in advance....

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If a user borrows USD from Coinbase or a Coinbase affiliate under a loan agreement and Coinbase sells the user's BTC collateral, Coinbase charges a 2% flat fee on the total transaction amount of that collateral sale....

Why it matters: This provision establishes a specific fee trigger tied to a collateral liquidation event, which occurs under circumstances of default or threshold breach as defined in the applicable loan agreement. The 2% fee is charged in addition to any loss the user may experience from the collateral sale itself....

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The schedule discloses that Coinbase may test and roll out fee and spread changes on a variable basis across different geographic regions, asset types, order sizes, and trade types, meaning different users may experience different fees for comparable transactions during testing periods....

Why it matters: This provision establishes that fees and spreads disclosed in the schedule are subject to change through testing processes that may produce different charges for different users based on region, asset, or order characteristics, without specifying notice requirements for individual users subject to tested changes....

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The policy states that personal information provided by users may be used to develop AI tools and systems, with the scope of that use governed by a separate document called the Postman AI Terms....

Why it matters: This provision authorizes a category of data use, AI tool and system development, that is governed by a separate document not included in this policy, meaning the full scope of AI-related data processing is not disclosed within the privacy policy itself. Legal and compliance teams reviewing Postman's data practices must separately obtain and assess the Postman AI Terms to understand the complete data use framework....

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The policy states that cookie-derived visitor information and hashed contact identifiers may be shared with or used by third parties for marketing and advertising purposes, while asserting that directly identifying information such as name and contact details is not sold to outside parties....

Why it matters: This provision distinguishes between the 'sale' of directly identifying data (which the policy states does not occur) and the disclosure of cookie-based visitor data and hashed contact identifiers to advertising partners (which the policy authorizes). Under CCPA and analogous state laws, disclosure of personal information for cross-context behavioral advertising may constitute 'sharing' regardless of whether monetary consideration is exchanged, and this provision may require evaluation under those definitions....

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The policy states that Postman personnel do not access private workspace content except for six enumerated purposes including security, support, service integrity, legal compliance, suspected law violations, and user consent, and that Postman may scan server content to detect security tokens, malware, known vulnerabilities, and Terms of Service violations....

Why it matters: This provision establishes the conditions under which Postman may access content stored in private workspaces, which for developer users frequently includes API keys, credentials, environment variables, and proprietary code. The scanning exception for security signatures, malware, and Terms of Service violations is operationally significant for enterprise customers with data confidentiality obligations....

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The policy states that when a user accesses Postman with a work email address, account information including name, profile picture, contact information, account content, and past usage history may become accessible to the employing organization's account administrator and other users on the same domain....

Why it matters: This provision establishes that associating a work email with a Postman account, including retroactively, may result in an employing organization's administrators gaining visibility into the user's account content and historical usage data. Users who created personal accounts before joining an organization and later associated a work email address may be affected....

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