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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Privacy Policy
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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Robinhood
· Robinhood Customer Agreement (PDF)
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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Robinhood
· Robinhood Customer Agreement (PDF)
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....