This Privacy Notice is provided in accordance with the Personal Data Protection Act 2012 (“PDPA”). It sets out how Robinhood Singapore Pte. Ltd. (“Robinhood”) collects, processes, and discloses your personal data in connection with our websites, apps, and other interactions in relation to our services (including when you are a prospective customer, customer, or former customer).

It also describes your data protection rights, including a right to access and correct your personal data held with Robinhood. More information about your rights, and how to exercise them, is set out in the “Your Data Subject Rights” section.

You may contact us at any time using the information set out in the “How to Contact Us” section.

We process personal data about you when you use our website, apps, and when you interact with us in relation to our services. This includes:

• Information you provide to us, such as information you submit via forms on our websites and apps and in surveys and focus groups and information you provide us if you contact us and information relating to our handling of your communication.

• Usage and tracking information. We and our service providers also use technologies, including cookies and web beacons and software development kits (“SDKs”), to automatically collect certain types of usage and device information when you use our services or interact with our emails. For example, the information collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information, and other similar information. For information about how to disable cookies, review Your Data Subject Rights.

We process the following categories of personal data in connection with our customers and our services:

• Identity and contact data, such as your name, date of birth, email address, mailing address, telephone number, marital status, other data from government-issued identification documents, and facial images for verification and authentication purposes.
• Financial data, such as your bank account and payment card details, and information about your income, account balances, securities holdings, financial transaction history, credit history, and tax information.
• Profile data, such as your username and password, your knowledge assessment results, and your interests and preferences.
• Marketing and advertising data, such as participation in focus groups, survey responses, contests/sweepstakes, your marketing choices, information regarding your preferences or attributes based on your use of our services, customer profiles and segments based on characteristics and combinations of characteristics, such as financial transaction history and holdings, and your interactions with advertising and marketing communications.
• Customer support and communication data, such as your feedback and interactions with our customer support teams and other communications you have with us.
• Service and transactional information. When you receive, submit, or complete a transaction via the services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.

We collect information you directly provide when you use our services. For example, data is collected through application and sign-ups, obtained from your use of our service, from forms completed by you, and from correspondence with you. Information about other sources of personal data is set out in “Third Party Sources” below.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to provide our services without this information. In other cases, provision of the requested personal data is optional, but this may affect your ability to procure or access certain functionalities or services where the information is needed for those purposes.

Where you are a website or app user, we collect information from advertising partners in connection with our ad campaigns that have surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.

When you participate in research, we obtain information that you provide our service providers and partners that are assisting us with market research from those service providers and partners as well as their analysis in relation to research contributions.

When you participate in offers, competitions, contests, sweepstakes or similar that we offer, we collect participation data from service providers and partners that we work with in relation to the offer or competition.

When you communicate or interact with us, our pages or brand on social media websites, we collect information about your communication or interaction from social media companies and service providers we engage in order to provide us analytics in relation to our social media pages and presence.

In relation to our customers and services, we also obtain information about you from third party sources as described below.

• Vendors and business partners. We collect contact and account information from technical, currency, payment and delivery service providers, fraud risk ratings, sanctions status, and related information from anti-fraud, anti-money laundering and sanctions reporting service providers, results of verification checks from providers of identity verification and related services, and attributes and interactions with different digital properties and advertisements from analytics and advertising service providers. We also use Google autofill features to help complete addresses during onboarding.
• Payment Services Providers. We support account linking and payment services through a third-party provider. We may receive details about your relationship and accounts with your financial institution.
• Connected services. If you link, connect, or log in to your Robinhood account with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service. We may also collect location data through these services if this feature is enabled.
• Publicly available data, such as contact information, social media content made public, sanctions lists and similar information.

We use cookies and similar technologies for the following purposes:

• Security and authentication — to verify your identity, maintain your session, protect your account, and detect fraudulent or unauthorised activity;
• Functionality and preferences — to enable core features of our services, remember your settings and preferences, and provide a consistent experience across devices;
• Analytics and performance — to understand how our services are used, measure traffic and engagement, diagnose technical issues, and improve the design, content, and functionality of our services;
• Personalisation — to tailor content, features, and communications to your interests; and
• Marketing and advertising — to measure the effectiveness of our marketing campaigns, deliver advertising that may be relevant to you on our services and on third-party websites and applications, and to compile statistics about advertising response rates.

Information Collected Through These Technologies

The information collected through cookies and similar technologies may include your IP address, browser type and version, internet service provider, device type and identifiers, including in some cases hashed contact information, operating system, referring and exit pages, pages and content viewed, links clicked, date and time stamps, approximate location derived from your IP address, and other usage information. For further detail on how this information is processed, please refer to the "Personal Data We Collect and How We Collect It" section above.

Your Choices

You may manage your preferences for cookies and similar technologies in the following ways:

In-product settings. Where applicable, you may opt out of certain cookies and similar technologies, including SDKs used for analytics and advertising purposes, through the privacy settings within our mobile and web applications. Cookies and similar technologies that are necessary for the operation, security, or core functionality of our services may not be disabled through these settings, as without them our services may not function properly.

Browser controls. Most web browsers allow you to refuse new cookies, delete existing cookies, or notify you when new cookies are set. The methods for doing so vary by browser; please refer to your browser's help documentation. For more general information about cookies and how to manage them, you may wish to visit https://www.allaboutcookies.org. You can also adjust your cookie preferences in relation to non-strictly necessary cookies by using the cookie banner on our Platforms or by using our Consent Management Platform.

Mobile device controls. Your mobile operating system may provide controls that allow you to limit ad tracking or reset your advertising identifier. Please refer to your device's settings for further information.

Email tracking. You may set your email client to prevent the automatic downloading of images, which may limit our ability to detect when you have opened or interacted with our emails.

Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.

Please note that if you disable or restrict cookies and similar technologies, certain features of our services may not function properly, you may need to re-enter information more frequently, and the content and advertising you receive may be less relevant to you.

We process personal data for the following general purposes relating to all users, and for specific purposes relating to our customers and services.

General Purposes:

• Security, Fraud Prevention, and Protection of Rights: Detecting, investigating, and preventing security or cyber incidents and fraud, and protecting and enforcing the rights, property, security, or safety of Robinhood, our business, our customers, or others.
• Legal and Regulatory Compliance: Fulfilling legal requirements, audit and investigative purposes, establishing or defending legal claims, and meeting required disclosures or requests from regulatory, governmental, tax, law enforcement authorities, courts, or tribunals.
• Marketing and Business Development: Sending you direct marketing (via in-app messaging, email, WhatsApp, or SMS), including newsletters, product announcements, and partner offerings; conducting, administrating, and fulfilling offers, surveys, contests, sweepstakes, or events; and conducting market research on our brand, products and services to understand how we can improve our brand, products and services and to inform our marketing and promotional strategies.
• Analysis and Optimization: Understanding how visitors and customers engage with our websites, apps, and services, and monitoring and improving their performance; optimizing system administration, operation, testing and support.
• Communications with the Public: Responding to and interacting with social media users and analyzing interaction with our social media pages and our brand on social media websites.

Customer-specific Purposes:

• Account Management: Processing account applications and performing our obligations under our contract with you, including managing accounts and billing, and providing contractually required service, relationship or transactional information.
• Customer Relationship Management: Managing our relationship with you, including notifying you about changes to our terms or this Privacy Notice, and handling and responding to customer support inquiries, queries, or complaints.
• Internal Risk Management: Identifying and managing financial, regulatory, and reputational risk.
• Legal, Regulatory, and Compliance: Complying with specific legal requirements such as "know your customer" (KYC), anti-money laundering (AML) rules, audit, tax records, sanctions checking, and politically exposed persons (PEP) screening; responding to requests from any regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals; making legally required disclosures to said entities; and establishing, exercising or defending legal claims, including enforcing and carrying our contracts and agreements.
• Product Experience Personalization: Personalizing our services, including suggesting and customizing content in the app.
• Marketing: Personalized advertising when permitted by your privacy choices, including through the use of cookies or similar technologies.

We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share personal data about you in the instances described below and for the other purposes described in this Privacy Notice.

Third-party service providers. We share information about you with our third-party service providers that perform services for us, such as fraud and crime prevention services, and sanctions screening, market research services, mailing services, tax and accounting services, customer support and account management services, backend engineering services, contest fulfillment services, market research services, web, platform and data hosting services and analytics services. We use an identification verification service provider to determine whether a selfie you take matches the photo in your government-issued identification and to gather information needed for any manual identity verification we carry out.

Payment Services Providers. We support account linking and payment services through a third-party provider. We may share details about your Robinhood relationship and accounts with your financial institution.

Marketing Partners. We disclose information about you to third-party advertising and marketing services, including as described in How We Use Cookies. For example, we may share personal data such as your hashed email address or your device ID with marketing partners to help us market Robinhood products to you across third-party websites and online services.

Companies in which you hold securities. We provide your name, address, email address, and securities positions to requesting companies in which you hold securities in relation to your rights and participation as a shareholder in those companies.

Robinhood affiliates. We share personal data about you with other companies in the Robinhood group. This includes sharing personal data with Robinhood group entities, including in the US, who provide infrastructure, operational, customer service, technical and IT services.

Sale of our business. We may share information about you in connection with a corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party and as part of any due diligence activities in relation to the foregoing, or in the unlikely event of a bankruptcy or similar proceeding.

Third parties in relation to legal claims: We disclose personal data to third parties as required in order to establish, exercise or defend or to protect legal claims, including in relation to our contracts with our customers and in order to protect the rights, property or safety of us, our business, our customers or others, including to legal advisors, government and law enforcement authorities, courts and tribunals and with other parties involved in, or contemplating, legal proceedings.

Regulatory, prosecuting, law enforcement, tax or governmental authorities, courts or tribunals. We disclose information about you to these third parties upon their request or as required by law as set out in Section 3 above.

With your consent. We share information about you for any other purposes disclosed to you with your consent.

As a U.S. headquartered company, most of our IT systems are hosted in the United States (including on third party systems). We also share personal data with our group companies in the U.S. As a result, we will transfer your personal data to this jurisdiction, including to our staff members who are located there.

We also may transfer your personal data to third parties that host or access personal data in various other jurisdictions, including countries in North America (e.g., Canada, Mexico), Europe (e.g., Germany, Ireland, UK, Switzerland, and others), South America (e.g., Argentina, Colombia), the Middle East (e.g., United Arab Emirates), and Asia (e.g., India, the Philippines).

With respect to our customers and our services, we retain most personal data for the duration of your relationship with us and a period of up to seven years after that. However, different personal data will be subject to different retention periods depending on the circumstances or applicable law.

You have the right to ask us for a copy of your personal data and to correct your personal data. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Robinhood processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person.

You can exercise your rights by contacting us using the details set out in How to Contact Us. You can also use our self-service tool by logging into your Robinhood account, navigating to the Security and Privacy menu, and selecting the option to Download Personal Data.

You can opt out of direct marketing at any time by contacting us using the information in How to Contact Us or by using the “unsubscribe” option in any direct marketing communication. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages. If you are receiving marketing or promotional text messages from us and wish to stop receiving them, you can respond with “STOP” to the number from which you received the message.

This Privacy Notice will evolve with time, and when we update it, we will revise the "Last Updated" entry above and post the new Privacy Notice and, in some cases, we provide additional notice (such as adding a statement to our website or sending you a notification). We may communicate any changes with you from time to time in a manner we determine.

If you have any questions about this Privacy Notice, wish to exercise your rights or wish to contact us for any other reason in relation to our personal data processing, please contact us at privacy@robinhood.com.