Robinhood - Applicant Privacy Notice
Last Updated: November 7, 2024
1. Purpose. This Notice (“Applicant Privacy Notice” or “Notice”) describes how Robinhood Markets, Inc., and its international affiliates Robinhood U.K. Ltd., Chartr Ltd., Robinhood Europe UAB, and Robinhood Canada Ltd. (collectively, “Robinhood,” “we,” or “us”) collects, uses, and discloses your (“Applicant,” “you,” or “your”) personal information in connection with your application for a job with Robinhood.
2. Robinhood Entity.
If your Country of Residence is the United States, your Robinhood entity is Robinhood Markets, Inc.
If your Country of Residence is Canada, your Robinhood entity is Robinhood Canada Ltd.
If your Country of Residence is within the European Economic Area, your Robinhood entity is Robinhood Europe, UAB.
If your Country of Residence is within the United Kingdom, your Robinhood entity is Robinhood UK Ltd. or Chartr Ltd.
3. Scope. This Notice applies to all Applicants. It covers Applicants’ “personal information,” or “personal data” as defined under the Applicant’s jurisdictional law. Residents of California, the European Economic Area (“EEA”), and the UK may consult information specific to their jurisdictions listed at the end of this Notice.
4. Personal Information We Collect. We may collect the following types of personal information in connection with your application for a job with Robinhood:
- Identifiers, such as your first and last name, contact information (including phone number, email address and home address), residency and location information, government-issued identification number, date of birth, and any identifiers you volunteer in your application materials, including in your CV, cover letter, references, job preferences, or as you otherwise volunteer on your public social media accounts, such as on LinkedIn or Facebook;
- Demographic information such as age, gender, and veteran status;
- Financial information, such as banking information, where we need to provide you with reimbursement during the recruitment process;
- Professional or employment-related information, including employment and education histories, language competencies, salary information, information about other roles applied to, references and referee contact information, position applied to (including location), assessments, test results, information gathered from interviews, including, as applicable, video and telephone interviews, details about how you heard about an opening, your willingness to relocate, job preferences, relationship to current Robinhood employee(s), if any, external board memberships or close personal relationships that may present conflict of interests risks, and any other information that you volunteer in connection with an application to work for Robinhood or when you communicate with Robinhood for an inquiry;
- Education information, such as academic qualifications and completed trainings;
- Network activity information, such as information collected when you interact with our Website, including information derived from our use of cookies on the Website, such as information about your IP address, location, device settings, log information, time of usage, browser information, operating system, username and account-related information, communication preferences, or any other information you may volunteer when you interact with us online and on our Website.
- Visual information, such as photographs in your CV, or video obtained through CCTV cameras when you enter Robinhood premises or are taken to events or otherwise in interviews for a job;
- Inferences drawn from the above, such as abilities and aptitudes.
We may also collect, use, and disclose the following types of personal information which, depending on your jurisdiction, may be considered sensitive personal information:
- Government-issued identification numbers, such as social security number, driver’s license number, or passport number;
- Health information, including information about medical conditions, accommodation needs, illness records, if we may need to accommodate you for a specific job, and disability information needed to comply with legal obligations and offered voluntarily in connection with diversity and anti-discrimination programs or offerings;
- Racial or ethnic origin, sexual orientation, or gender identity as needed to comply with legal obligations and internal policies relating to diversity and anti-discrimination;
- Work permit information, such as work visa or other information related to work eligibility, including citizenship status, provided that such information or documents are required under applicable laws
- Records of criminal convictions and offenses committed by Applicants (provided that a criminal background check is mandatory given the role or function being applied to).
5. Sources of personal information. Robinhood collects the majority of the above information directly from Applicants but may also collect information from other sources. For example, during our recruitment process, we may request references from third parties as may be permitted by law (such as your former employers, colleagues, or managers) and carry out screening and vetting processes using third-party sources. If Robinhood wants to contact your current employer for reference or screening purposes, we will do so with your written confirmation where required by law. We may also collect personal information from recruitment agencies if you are applying through one.
If a current Robinhood employee refers you for a position, depending on the information submitted we may collect your contact information, resume, the job for which you are being referred, education history, current position, and LinkedIn profile. We will reach out to you by email to confirm receipt of the referral. We may notify the referring employee of the status of your application.
From time to time, Robinhood may receive personal information about you from other third parties (for example, customers or business partners).
6. Use of Personal Information. To the extent permitted by law, we may use or process your personal information for the following purposes. The legal bases for processing your personal information, where required by law, are also provided.
Purpose
Legal Basis
Categories of Personal Information Involved
- Identifiers;
- Professional or employment-related information;
- Education information;
- Work permit information;
- Inferences from the above; and
- Any other personal information you volunteer in your application or communications with Robinhood
Evaluation of Applications. To evaluate your qualification, suitability, and fit for applicable jobs and opportunities with us
Applicant’s consent
Application processing and recruitment. To facilitate access to our Website, submission, transmission and efficient processing of applications, coordinating interviews and recruitment events, including any related travel and meals
Applicant’s consent
- Identifiers;
- Professional or employment-related information;
- Education information; and
- Inferences from the above
- Identifiers; and
- Professional or employment-related information
Communication and updates. To respond to your inquiries and communicate with you about your application, and to send you information regarding our careers page and changes to our terms and policies
Applicant’s consent
- Identifiers; and
- Professional or employment-related information
References. To contact references to obtain additional information about your suitability as a candidate
Applicant’s consent
- Identifiers;
- Professional or employment-related information;
- Education information;
- Government-issued identification numbers;
- Work permit information; and
- Records of criminal convictions and offenses
Application verifications and background checks. If we offer you or intend to offer you a position, and it is required for the role, conduct verifications and background checks, including by contacting references, to confirm the veracity of application details, such as education, experience, work authorization and qualifications, and in some countries, to obtain a criminal background history.
Legitimate interest
Compliance with legal obligation
- Identifiers;
- Demographic information;
- Professional or employment-related information;
- Education information;
- Health information; and
- Racial or ethnic origin, sexual orientation, or gender identity
Diversity and inclusion. To monitor and foster equal opportunity in recruitment processes, including to comply with related applicable laws and regulations
Applicant’s consent
Legal obligation
- Identifiers;
- Professional or employment-related information;
- Education information;
- Government-issued identification numbers;
- Health information; and
- Work permit information
Compliance. To otherwise comply with applicable legal, regulatory, or contractual requirements, including conducting audits to verify that our internal processes function as intended, identifying potential conflicts of interest, and managing and further mitigating subsequent risks
Legal obligation
- Identifiers;
- Professional or employment-related information;
- Education information;
- Government-issued identification numbers; and
- Work permit information
Legitimate interest
Improving Recruiting Processes. To identify opportunities and implement changes to make our recruitment processes more effective, efficient and engaging, including through analytics and aggregate reporting, and screen or adopt new technologies.
- Identifiers;
- Professional or employment-related information; and
- Education information
Future opportunities. To create an online profile about you based on your capabilities and qualifications that can be used to identify additional professional opportunities that may be of interest to you.
Applicant’s consent
Legitimate interest
- Identifiers;
- Professional or employment-related information;
- Education information;
- Network activity information;
- Visual information; and
- Work permit information
General business operations. To carry out legitimate internal business activities, such as internal training, monitoring for and preventing fraud, and detecting and preventing cyberattacks, pursuing or defending legal claims, and planning for commercial transactions
Legitimate interest
- Identifiers; and
- Financial information
Applicant’s consent
Reimbursement. To reimburse certain Applicant’s expenses during the recruitment process
If you provide Robinhood with other persons’ details, you should inform those persons and introduce them to the provisions of this Applicant Privacy Notice.
If you do not provide Robinhood with the personal information necessary for recruitment 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.
7. Disclosure of Personal Information. To the extent permitted by law, we may disclose or transfer your personal information in the following manners:
- With our affiliates or group companies for their independent purpose in facilitating planning and resource allocation between companies, policy development, financial reporting and similar legitimate business interests of our affiliates or group of companies;
- With companies that supply or perform services for Robinhood or its personnel, including employee benefits providers, recruitment agencies, payment service providers, workforce management providers, and background check providers of Robinhood;
- 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 and external legal counsel as necessary to protect Robinhood’s corporate assets from theft, fraud, or damage; and
- With other third parties for their own purposes with your consent.
We require third parties to respect the security of your personal information and to treat it in accordance with the law. All our service providers, our affiliates, and our group companies are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our service providers to use your personal information for their own purposes.
8. Information about criminal convictions. Where authorized by applicable law, and reasonably required for a certain position with us, we may either use a service provider to carry out checks of any criminal convictions (or select criminal convictions, depending on the case) as part of performing background checks on Applicants. We may also ask you to make a confirmatory statement in that regard or to provide official certificates obtained from public authorities. As a regulated company, this information enables us to make decisions about recruitment and to execute the purposes for collecting, using, and disclosing your personal information pursuant to this Applicant Privacy Notice. In cases where using service providers is allowed, and we decide to engage a service provider to carry out such checks, our service provider will ask for your consent to these checks being carried out on our behalf.
9. Retention. We will only retain your personal information for as long as is necessary to fulfill the purpose of collection, as required under applicable laws. If you accept an offer from Robinhood, your personal information will be retained for the duration of your employment with Robinhood. Robinhood may in some cases store your personal information longer:
- if necessary, to enable Robinhood to defend itself against claims and exercise its rights to issue claims or lawsuits;
- if there are reasonable suspicions of illegal activity;
- if personal information is necessary for proper resolution of a dispute or complaint;
- if your request for access to your personal information is received; or
- on other grounds provided for in applicable data protection law.
10. Third-Party Sites - Our Website may contain links to other sites, such as Greenhouse or LinkedIn. We are not responsible for the privacy practices of third parties. You should review the privacy policies of any such third parties before sharing any of your personal information.
11. Contact Details - You may contact us with questions about this notice or how we handle your personal information by contacting our Data Privacy Officer by email at employeeprivacy@robinhood.com. You may also contact us with questions via postal mail to Robinhood at 85 Willow Rd, Menlo Park, CA 94025.
12. Changes to this Notice - We may update this Applicant Privacy Notice from time to time to take into consideration changes in legislation, regulatory guidance, or business practices. If we update this Applicant Privacy Notice, we will post the latest version on our Website.
13. Notice to Residents of California, the EEA, and the UK.
Your Rights. Subject to limitations, you have the following rights related to your personal information:
- Request access to the personal information we hold about you (commonly known as making a “data subject access request”);
- Request to correct personal information about you that is inaccurate, incomplete, or outdated; and
- Request to delete your personal information, enabling you to ask us to erase or remove personal information where there is no good reason for us to continue to keep it.
You may exercise these rights by filling out this form or contacting employeeprivacy@robinhood.com.
Residents of the EEA and the UK also have the right to withdraw consent for processing their personal information in the rare instances where it is the legal basis for processing. They additionally have the rights to object to the processing of their personal information and to request the restriction of the processing of their personal information.
If you make a request to exercise the rights referenced above, we may require you to provide certain information for identity verification purposes. Residents of California may authorize an agent to make a request to us on their behalf, and we may verify the identity of their agent or authorized legal representative by seeking either confirmation from them or documents that establish the agent’s authorization to act on their behalf. You have the right to be free from discrimination when exercising any of the above rights.You also have the right to complain to the relevant supervisory authority designated below. However, we encourage you to first contact us for any questions about the way your personal information is processed at employeeprivacy@robinhood.com.
Sales of Personal Information. We do not sell or share your personal information as those terms are defined under California law. We also do not process sensitive personal information other than for the limited purposes authorized by California law without the right to limit.
Overseas transfers. As a company headquartered in the US, most of our IT systems are located in the US and most of the information described in this policy above is hosted in the US with us or our vendors. We transfer this information out of your jurisdiction with appropriate safeguards in place, such as the EU and UK Standard Contractual Clauses.
Cookies. Robinhood does not place nonessential cookies for users in the EEA and UK without their consent.
Contact Details - Applicants may contact Robinhood at employeeprivacy@robinhood.com or you may contact our DPO at dpo@robinhood.com, or by postal mail at:
Jurisdiction
Supervisory Authority
EEA
United Kingdom
Company
Address
85 Willow Road, Menlo Park, CA 94025 United States
Robinhood Markets, Inc.
Vilnius, Mėsinių g. 5, 01135 Vilnius,
Lithuania
Robinhood Europe, UAB
70 Saint Mary Axe Suite 307, London, England EC3A 8BE
Robinhood U.K. Ltd. and Chartr Ltd.
100 King Street West, Suite 600, 1 First Canadian Place, Toronto, Ontario, Canada, M5X1E2
Robinhood Canada Ltd.