Robinhood GDPR

Last updated: 1 September 2023

1. Purpose - Robinhood Markets, Robinhood U.K. Ltd, and Robinhood Europe, UAB, legal entity code 306377915, registered at Mėsinių str. 5, Vilnius, the Republic of Lithuania (collectively, “Robinhood”) value and respect the privacy of their applicants. This policy describes the privacy practices of Robinhood in connection with the personal data collected about its applicants.

Any personal data Robinhood gathers, uses, or shares about applicants is processed in accordance with the Regulation (EU) 2016/679 of the European Parliament, the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR“), Law on legal protection of personal data of the Republic of Lithuania and other applicable legal acts.

2. Scope - This policy applies to the processing of personal data by Robinhood relating to any individual that applies to work for Robinhood and who is located in the United Kingdom or a Member State of the European Union (“applicants” or “you”).

3. Collection of Personal Data - depending on the job position, Robinhood collects various types of personal data. The following are the main categories of personal data about applicants:

Personal identification data: name, surname, date of birth (age) and government-issued identification number;
Contact information: phone number, email and physical address;
Information on qualification and experience: professional or employment-related information and education information submitted in connection with an application to work for Robinhood (such as employment history, work experience, qualifications, education history);
Recommendations, employers' feedback – referees’ contact details, references, content of the feedback or recommendation;
Records of criminal convictions and offenses (only if such personal data is necessary to verify whether the person fulfils the requirements for the performance of job functions or the requirements for a position as laid down by the legal acts) and processed prior to extending an offer;
Visual information: photographs in your curriculum vitae (CV), or video obtained through CCTV cameras when arriving for on-site interviews;
Financial information: banking information, where we need to provide you with reimbursement during the recruitment process;
Work permit data: work visa or other information related to work eligibility;
Evaluation information: summary of your job interview, comments, tests, tasks performed, and the results of any of the aforementioned evaluations (if carried out), inferences drawn related to potential work performance, including abilities and aptitudes;
Personal data revealing racial or ethnic origin information, where permitted by local law needed to comply with legal obligations and internal policies relating to diversity and anti-discrimination; and
Disability information, only if such personal data is necessary to verify the applicant's ability to perform certain job functions and/or if the applicant chooses to provide such information.

Robinhood collects the majority of the above information directly from applicants but may also collect information from other sources. For instance, during the recruitment process, Robinhood may request references from third parties (such as applicants’ former employers, colleagues or managers) and carry out screening and vetting processes using third-party sources. We may also collect applicants’ personal data from recruitment agencies if they are applying through one. Robinhood also generates some information from its applicants, such as inferences raised about the applicant’s prospects for employment and notes made during an interview with an applicant. Additionally, personal data may be collected indirectly (for example, building and location access control and CCTV footage may be obtained when applicants visit our offices), if and to the extent permitted by applicable laws.

4. Purposes for Processing - the table below sets out the purposes of processing your personal data, the legal bases, and the category of processed personal data:

If you provide Robinhood with other persons’ details, you should inform these persons and introduce them to the provisions of this policy.

If you do not provide Robinhood with the personal data necessary for recruitment (selection) purposes or later for the conclusion and / or execution of a contract, Robinhood will not be able to consider your candidacy for the respective position, to conclude a contract with you, or perform other related functions.

as necessary for compliance with a legal obligation, such as to comply with financial and employment regulatory requirements (including to process your identifiers and background check information);
as necessary in order to take steps at the request of the applicant prior to entering into a contract (including to process your identifiers, professional or employment-related information, and your background check information);
as necessary in order to protect the vital interests of the applicant or of another natural person, such as an emergency where the health or security of an applicant or other person is in danger during or after an on-site visit (including to process your identifiers); and
for the following legitimate interests: evaluation of your suitability for the role you are applying for, to communicate with you as needed during the interview process, to evaluate, analyse, and report on the recruitment process, and protection of Robinhood’s network and property (including to process your identifiers, professional or employment-related information and inferences as may be needed).

5. Disclosure of Personal Data - Robinhood shares personal data about its applicants as follows:

with its affiliates and subsidiaries in facilitating planning and resource allocation, policy development, financial reporting, and similar legitimate business interests of the Robinhood family of companies;
with companies that perform services to Robinhood or to applicants, including recruitment agencies, payment service providers, and pre-screening check providers (e.g., Checkr to verify the authenticity of applicant’s documents relating to his identity, education, and work experience, as well as to check the applicant’s records of criminal convictions and offenses to verify if he/she fulfils the requirements laid down by laws);
as part of, or during negotiations of, any merger or sale of Robinhood assets;
with regulatory authorities or other third parties where Robinhood believes disclosure is required by applicable law and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
with law enforcement authorities as necessary to protect Robinhood’s corporate assets from theft, fraud or damage; and
the State Social Insurance Fund Board, law enforcement agencies, other registers, and state authorities, if applicable.

6. Data Subject Rights - Subject to certain limitations and exceptions, applicants have a number of legal rights regarding Robinhood’s processing of personal data that relates to them, as further described below.

A right of access: applicants have the right to request access to, or a copy of, the personal data Robinhood processes about them (subject to some limited exceptions which may mean we may not be able to provide the applicant with all the personal data that we process).
A right of rectification: applicants have the right to request that Robinhood correct or supplement inaccurate or incomplete personal data it processes about them.
A right of erasure: applicants have the right to request that Robinhood delete personal data in certain contexts (such as where the data is no longer necessary in relation to the purposes for which it was collected).
A right to restriction of processing: applicants have the right to request that Robinhood restrict processing of personal data in certain cases (such as if Robinhood no longer needs to process the data for its purposes, but the data subject requires the data for legal claims), so that Robinhood can store such data, but not further process it.
A right to data portability: in certain cases (such as where processing is based on performance of contract and is undertaken with automated means), applicants have the right to request personal data they have provided to Robinhood to be delivered to them in a structured, commonly used, and machine-readable format, so that the they can transmit such data to another controller without hindrance from Robinhood.
A right to object to processing: applicants have the right to request that Robinhood stop processing personal data in certain contexts (such as if objecting to a specific processing activity undertaken in Robinhood’s legitimate interests unless Robinhood has compelling legitimate grounds for the processing that override the applicant’s concerns).
A right to revoke consent: When processing is based on consent, applicants have the right to revoke such consent at any time.
The right to file a complaint: applicants have the right to file a complaint regarding Robinhood’s data protection practices with the relevant supervisory authority. If you are in the UK, please see the ICO contact information at: https://ico.org.uk/global/contact-us/. If you are in the EEA, please see this directory: https://edpb.europa.eu/about-edpb/board/members_en.

In the limited circumstances where we rely on your consent to use your information, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent you may contact Robinhood via the e-mail address provided in paragraph 9 of this policy.

Robinhood shall make all possible efforts to exercise your rights and to answer any questions you may have regarding the information contained in the policy. You may submit a request for the exercise of your rights via the e-mail address provided in paragraph 9 of this policy.

In order to exercise his/her rights, the applicant must be successfully identified by Robinhood; therefore, Robinhood may ask you to provide proof of your identity or use other legitimate means of identification.

Robinhood will respond to your request no later than 1 (one) month from the date of receipt of the request. In exceptional cases, where additional time is required, Robinhood will notify you and will have the right to extend the deadline for examination of your request for 2 (two) more months.

Robinhood may refuse to comply with your request only on reasonable grounds if the circumstances specified in the GDPR and other applicable laws have been established by informing you in writing. The answer shall be provided to you via email, unless you will indicate another preferred form.

7. Retention of Personal Data - Robinhood will erase or render anonymous personal data when the processing is no longer necessary, and applicable law no longer requires Robinhood to retain it.

If your application for a job position is not successful, then the personal data that you have provided will be stored until the end of the recruitment process and as further informed by applicable law.

If you are not invited to work for Robinhood this time, with your consent, we would like to store your application documents and the personal data provided in them for evaluation during other recruitment processes, when looking for a similarly qualified employee.

If you agree, Robinhood will process the personal data provided in your application documents relating to qualifications, abilities and professional skills, as well as the contact details needed to contact you. We will store the submitted data for the above purpose for 1 (one) year from the date of giving this consent, unless you request its deletion earlier.

If you have been selected by Robinhood as suitable for a position, the information you provided for the recruitment purposes will be further processed by Robinhood for internal administration purposes on the basis of the concluded employment contract.

Robinhood may in some cases store your personal data longer:

if necessary, to enable Robinhood to defend itself against claims and exercise its rights to issue claims or lawsuits;
there are reasonable suspicions of illegal activity;
personal data is necessary for proper resolution of a dispute or complaint;
your request for access to your personal data is received;
on other grounds provided for in the legislation.

8. Cross-Border Transfer of Personal Data - Robinhood transfers personal data originating from the UK and EEA to the United States and other countries, which may not provide equivalent levels of data protection as the originating jurisdiction. Any transfer of this data to a country which the UK or the European Commission (as applicable) does not recognize as having an adequate level of protection will be conducted pursuant to the standard contractual clauses entered into by the Robinhood group, a copy of which may be made available upon request.

9. Contact Details - applicants may contact Robinhood UK (which serves as the representative of other Robinhood affiliates) with questions or complaints at privacy_uk@robinhood.com

10. Data Controller - Robinhood is the controller of your personal data.

11. Policy updates - this policy may be changed, amended, or renewed at any time. If Robinhood makes substantial changes to this policy, you will be informed.

Personal identification data;
Contact information;
Information on qualification and experience;
Recommendations, employers’ feedback;
Evaluation information;
Work permit data (to assess the legal basis for working and staying in UK/EEA and to assist in obtaining such basis if the applicant does not have it (if the applicant is a foreigner));
Visual information (photographs in applicant’s curriculum vitae (CV) if provided);
Records of criminal convictions and offenses (only if such personal data is necessary to comply with local law or to verify whether the applicant fulfils the requirements as laid down by the laws);
Disability information (if it affects the ability to perform job functions and the applicant provides this information voluntarily);
Other provided information.

Personal identification data;
Contact information;
Visual information (photographs in applicant’s curriculum vitae (CV) if provided);
Information on qualification and experience;
Recommendations, employers’ feedback;
Evaluation information;
Work permit data (to assess the legal basis for working and staying in UK/EEA and to assist in obtaining such basis if the applicant does not have it (if the applicant is a foreigner));
Records of criminal convictions and offenses (only if such personal data is necessary to comply with local law or to verify whether the applicant fulfils the requirements as laid down by the laws);
Disability information (if it affects the ability to perform job functions and the applicant provides this information voluntarily);
Other provided information.