This Privacy Statement (“Privacy Statement”) explains how Robinhood (as defined below) handles personal information in connection with the child’s Trump Account.

In this Privacy Statement:

• You are referred to as the “Responsible Party,”
• The child is referred to as the “Account Beneficiary,”
• The child’s account is referred to as the “Account,” and
• Robinhood Securities LLC (the “Trustee”); Robinhood Financial LLC (the “Broker-Dealer”) (collectively “Robinhood” or “we”).

The personally identifiable financial information we collect, and process is generally subject to a law called the Gramm-Leach-Bliley Act (the “GLBA”). You can review the GLBA-financial privacy notice. This Privacy Statement supplements our GLBA-financial privacy notice to provide more information about our data handling practices online. This Privacy Statement applies to mobile apps, websites, and other online services that provide features or functionality for the Account Beneficiary and the Responsible Party. Unless otherwise defined here, capitalized terms have the meanings given in this Privacy Statement.

A Trump Account is a type of traditional Individual Retirement Account with some special rules, as discussed in the Trump Account Trust Agreement (“Trust Agreement”). For a plain language explanation of the Account, including the rules, benefits, and important legal information about the Account, consult the Trump Account Disclosure Statement (“Disclosure Statement”). The Trust Agreement provides important legal and federal tax information about the Account, including a description of the special rules that apply to the Account. This Supplemental Statement should be read together with the Trust Agreement. This Account was established pursuant to an election made on IRS Form 4547 or opened by the U.S. Department of the Treasury (“Treasury”) on your child's behalf based on eligibility criteria (such as age and Social Security Number), and operates as a federal program administered by Treasury with support from its agent, The Bank of New York Mellon (“Financial Agent”). Robinhood Securities LLC has been designated as the Trustee of this Account, acting on behalf of Treasury and through the Financial Agent.

We collect information provided by the Responsible Party regarding themselves and the Account Beneficiary, when they use, apply to use or engage with, the Account, such as:

• Identity Data, such as your name, date of birth, marital status, social security number, selfies/photographs/videos, government-issued identification documents, and other data on government-issued identification documents;
• Contact Data, such as your email address, mailing address, and telephone number;
• Profile Data, such as your username and password;
• Information you provide us when sending a contribution: We collect information (including name, email address or phone number, and payment information) from the individual or entity contributing to the Account;

We also collect certain information about the Responsible Party and the Account Beneficiary automatically when the Account is used, such as:

• Usage Information: We collect information about your activity on the Account, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
• Transactional Information: When a transaction is received, submitted, or completed via the Account, we collect information such as transaction amount, type and nature of the transaction, time and date of the transaction.
• Information Collected Through Tracking Technologies: We, and some of our service providers and third-party partners, use technologies, including cookies and web beacons and software development kits, to automatically collect certain types of usage and device information.
• Biometric Data: We extract facial geometry data from selfies/photographs/videos to verify your identity and detect/prevent fraud.

We may transmit a subset of Account‑related information from our systems to Treasury and to the Financial Agent, as the case may be. Shared Information may be used to:

• Open, administer, and service the Account;
• Verify eligibility for the Account under applicable law;
• Support Treasury’s reporting, oversight, and operations of the Account; and
• Comply with applicable laws, regulations, and Treasury instructions.

Account information sent to Treasury is subject to key safeguards:

• Data minimization: Only information that the Treasury has determined is necessary for the purposes above is sent to the Treasury.
• One‑way transmission: If the Account was opened by Treasury on behalf of an Account Beneficiary, Treasury will verify eligibility and identity information with us when the Responsible Party claims the Account. When the Account is claimed by a Responsible Party and a brokerage account is opened with us, the Account Beneficiary’s information is transmitted from our brokerage systems to the Treasury only, and information maintained in Treasury systems is not transmitted back to our brokerage systems.
• Separate systems: Our brokerage platforms remain separate from Treasury systems and do not become government systems as a result of this limited data sharing.

If the Account is rolled over or transferred to a different Trump Account, information related to the Account will continue to be handled under this Privacy Statement. However, we will retain data consistent with data minimization and deletion policies as required under federal law and as instructed by Treasury.

The Responsible Party or the Account Beneficiary may open or maintain other Robinhood accounts or services. This includes accounts or services that are related to the Account, including:

• Supplemental Account established if this Account receives excess funds; or
• Successor IRA that is automatically created after the Account Beneficiary turns 18.

The terms “Supplemental Account” and “Successor IRA” have the meaning that is set forth in the Trust Agreement.

If you open or maintain other Robinhood accounts or services other than this Account:

• Those accounts are governed by Robinhood’s Privacy Statement and applicable laws.
• Information used solely to administer the Trump Account is not used to administer non‑Trump Account accounts, except as permitted by law.

In limited circumstances, and only to the extent permitted by Treasury, certain information about the Account may also be used by us for operational purposes, such as:

• Improving user experience, including account onboarding flows, identification verification, customer support tools, and platform usability;
• Measuring and improving system performance, reliability, and availability;
• Conducting internal analytics and quality assurance related to Account operations;
• Enhancing fraud prevention, security monitoring, and risk management; and
• Debugging, testing, and maintaining Account related features and integrations.

We do not use the Account information for advertising or marketing.

Your Account‑related information will be shared:

• As discussed in this Privacy Statement,
• With service providers supporting the Broker-Dealer operations, consistent with this Privacy Statement, or
• As required by applicable law.

Robinhood may not sell information related to the Account.

Treasury and its authorized financial service providers may contact you by email, text message, or automated phone call regarding Trump Account activation and administration.

If you need help with account activation, you can call the Trump Accounts support team at 1-866-USA-4547. If you are unsure whether a communication is legitimate, visit TrumpAccounts.gov rather than responding directly to the message. Treasury and its service providers will never ask you to disclose passwords, one-time verification codes, or other sensitive account credentials by text message or phone call.

When you enter your mobile number in the Trump Account app and select the option to enable SMS two-factor authentication, you will receive a text message containing a one-time verification code: this code is required to complete login or security-sensitive actions within your Account. In alternative you can choose to receive an automated phone call containing the one-time verification code.

By opting in, you authorize us to send SMS messages to, or call the phone number you provided. You will only receive one SMS message or one call when you initiate an action on your Account that requires verification; message or call frequency depends on the actions you take on your Account. Message and data rates may apply to the SMS service, please refer to your carrier for more information on your plan. Carriers are not liable for delayed and/or undelivered messages.

You may opt out of the SMS two-factor authentication at any time by replying “STOP”. Please note that opting out of the SMS two-factor authentication may prevent you from logging into your Account via SMS verification. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed and you will no longer receive SMS messages from us. If you want to join again, please enable the SMS two-factor authentication in the Trump Account application, and we will start sending SMS messages to you again.

If you experience issues with the SMS service, you can reply “HELP” to the message to receive assistance or contact us at privacy@trumpaccount.com.

The SMS-based authentication service is used solely to verify your identity. We do not sell to, or share this information with, any third parties or affiliates for their marketing or promotional purposes.

Your Account information constitutes financial data governed by the GLBA, the federal financial privacy law. The GLBA applies to financial institutions, including the Financial Agent and Trustee for Trump Accounts. State privacy laws such as the California Consumer Privacy Act (“CCPA”) do not apply to Account-related information. Data retention rules for Account-related information are set by federal law and Treasury guidance, not state privacy laws. Information maintained in Treasury systems is retained consistent with data minimization and deletion policies as required under federal law and as instructed by Treasury. As a consequence, we cannot fulfill requests to access or delete Account information.

We retain your Account-related information for as long as necessary to operate the Account and to comply with Treasury guidance and relevant applicable laws. For example, we may retain certain data for the duration of your relationship with us and for a period of up to 7 years after the relationship ends in order to comply with our obligations as a regulated financial institution. We may also keep Account-related information for a longer period, with Treasury’s consent, if required by law, or in connection with an ongoing or potential claim.

We may update this Privacy Statement from time to time to reflect changes to the Account, legal requirements, or Treasury guidance. If we make material changes, we will update the “Last updated” date above and provide notice as required by law.

If you have questions about this Privacy Statement, including about how to exercise your privacy rights, contact us at privacy@trumpaccount.com.