Robinhood Canada Applicant Privacy Policy

Last Updated: December 11, 2023

1. Purpose. This applicant privacy policy (“Applicant Privacy Policy”) describes how Robinhood Markets, Inc. and its affiliates (collectively, “Robinhood”, “we” or “us”) collect, use, and disclose personal information of data subjects in connection with their application for a job with Robinhood (“Applicant”, “you”, or “your”), whether you share your personal information with us on www.robinhood.com (“Website”), in communications with us, or by other means in connection with your job application.

2. Scope. This Applicant Privacy Policy applies to Applicants located in Canada or in connection with their job application with a Robinhood entity or affiliate in Canada.

3. Important notice for minors. We do not knowingly collect, use, or disclose personal information of individuals under the age of 14. If you are under the age of 14, or do not understand or agree with this Applicant Privacy Policy, please do not share or disclose any of your personal information with us (i.e., any information that could allow you to be personally identified, either directly or indirectly). By sharing any of your personal information with us, whether via our Website or by any other means, you consent to the contents of this Applicant Privacy Policy.

4. Types of personal information we collect from you. We may collect the following types of personal information from you 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, 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;

Work and education background information, including employment and education histories, completed trainings, language competencies, salary information, information about other roles applied to, 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;

Job application information, including references and referee contact information, 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, or any other personal information that you may volunteer to us in a job application or communication to Robinhood;

Visual information, such as photographs or video obtained through CCTV cameras when you enter Robinhood premises or are taken to events or otherwise in interviews for a job;

Work permit information, including work visa or other information related to work eligibility, provided that such information or documents are required under applicable laws;

Inferences drawn from application materials relating to a job, such as abilities and aptitudes;

Information we receive about you from third parties, such as recruitment firms, employee referrals, and pre-employment screening service providers; and

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.

We may also collect, use, and disclose the following sensitive types of personal information:

Health information, including information about medical conditions, accommodation needs, illness records, if we may need to accommodate you for a specific job;

Personal information revealing racial or ethnic origin information as needed to comply with legal obligations and internal policies relating to diversity and anti-discrimination;

Disability information as needed to comply with legal obligations (if disclosed voluntarily by you);

Records of criminal convictions and offences committed by Applicants (provided that a criminal background check is mandatory given the role or function being applied to;

We may also collect personal information from third parties. 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. We may also collect personal information from recruitment agencies if you are applying through one. Robinhood also receives information from its own personnel (for example, in respect of performance reviews or in the course of conducting a disciplinary investigation). From time to time, Robinhood may receive personal information about you from other third parties (for example, customers, business partners or regulatory bodies), medical reports from external professionals, tax authorities, or benefit providers, if and to the extent permitted by applicable laws.

5. How we use or process your personal information. To the extent permitted by law, we may use or process your personal information for the following purposes:

6. How we disclose or transfer your 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 company assets;

with regulatory authorities or other third parties, inside or outside of Canada, 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

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.

Personal Information collected from you may be transferred or disclosed outside of the province or territory in which it was collected, including to service providers outside of Canada. In particular, your personal information may be transferred to service providers in the following countries: United States and the United Kingdom.

7. 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 Policy. 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 always ask for your consent to these checks being carried out on our behalf.

8. Automated decision-making. We do not carry out any automated decision-making about you.

9. Your rights. Under certain circumstances, by law, you have the right to:

Request access to personal information we hold about you;

Request correction of the personal information that we hold about you. This enables you to correct inaccurate or incomplete information we hold about you;

Request a withdraw of your consent to personal information we process from you;

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you;

Request the transfer of your personal information to another party in a structured, commonly used and machine-readable format.

10. Retention of personal information. We will only retain your personal information for as long as is necessary to fulfil the purpose of collection or as required under applicable laws.

11. Cookies. Our Website uses and allows third party cookies (session and persistent), pixels/tags, and other Website interface tracking technologies (collectively, “Cookies“) that collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the Website, while others are used to provide you with a better user experience, such as:

to allow you to use the Website and to personalize the Website by remembering information about your activities on the Website;

to perform website analytics, to understand how our Website is used, to improve the user experience and quality of the Website; and

to provide you career opportunities tailored to your interest.

Please review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have regarding Cookies. If you disable or delete certain Cookies in your Internet browser settings, certain features of the Website you visit may not be available or operate correctly.

12. Third-Party Sites. Our Website may contain links to other sites. We are not responsible for the privacy practices of third parties that do not supply or provide services to us. You should review the privacy policies of any such third parties before sharing any of your personal information.

13. Contact Details. You may contact us with questions about this policy or how we handle your personal information by completing this form or by contacting our Data Privacy Officer, Micahel Hauser, by email using the following email address: michael.hauser@robinhood.com. You may also contact us with questions via postal mail to Robinhood at 85 Willow Rd, Menlo Park, CA 94025. You have the right to make a complaint at any time to the relevant supervisory authority with respect to data protection.

15. Changes to this Applicant Privacy Policy. We may update this Applicant Privacy Policy from time to time to take into consideration changes in legislation, regulatory guidance, or business practices. If we update this Applicant Privacy Policy, we will post the latest version on our Website.

Robinhood - Canada Applicant Privacy Policy