**AI AGENT AGREEMENT**

**EMPLOYEE TESTING AGREEMENT**

**EMPLOYEE TESTING NOTICE**

**THIS IS A PRE-RELEASE VERSION OF THE AI AGENT ("AGENT") PROVIDED FOR INTERNAL EMPLOYEE TESTING PURPOSES ONLY.**

By accepting this agreement, you acknowledge:

**Voluntary Participation:** Participation is strictly voluntary and you can opt out at any time. Choosing not to test the Agent will have no impact on your employment.

**Testing Purpose:** You are accessing the Agent as a Robinhood employee or authorized tester for the sole purpose of evaluating and testing the product prior to any public release. This Agreement governs your use of the Agent during the testing phase. For clarity: (a) data you generate through account activity (trades, positions, balances) is processed under Robinhood's customer privacy framework, including the Robinhood US User Privacy Statement, the Financial Privacy Notice, and applicable financial privacy laws including the Gramm-Leach-Bliley Act; (b) data generated in your capacity as a tester (feedback, bug reports, interactions logged for product improvement) is processed under Robinhood's employee data practices, including the Personnel Privacy Notice. Where data falls into both categories, the more protective framework applies. 

**Pre-Production Status:** The Agent is in active development and has not been released to the public. The version you are using may contain bugs, errors, incomplete features, or other issues, and its behavior may be unpredictable. Features, functionality, available models, skills, tools, safety controls, and all other aspects of the Agent are subject to change without notice during the testing period.

**What the Agent Is:** The Agent is a first-party experience powered by a third-party large language model ("LLM") that Robinhood makes available in the Robinhood app and that operates within a dedicated agentic trading account. The Agent is composed of an LLM together with tools that connect it to Robinhood's trading infrastructure, skills, and memory. Robinhood does not own, develop, or train the LLM. While you may be able to choose different models in the future, the testing phase uses a fixed model. Robinhood provides and operates the surrounding platform, including the account connectivity, tools, skills, and interface, but Robinhood does not author or endorse the Agent's responses. The Agent's output is generated by the third-party LLM, not by Robinhood, and does not represent Robinhood's views or recommendations. In response to your prompts, or autonomously when enabled, the Agent can take automated actions on your account, including placing trades.

**Confidentiality:** Your access to this pre-release version is confidential. You agree not to disclose, discuss, or share information about the Agent's features, functionality, limitations, or your testing experience with anyone outside of authorized Robinhood personnel without prior written approval.

**Feedback and Reporting:** You are encouraged to report bugs, errors, unexpected behavior, and concerns through the designated internal channels. Your feedback will help improve the product.

**PLEASE READ THIS AGREEMENT ("AGREEMENT") CAREFULLY BEFORE USING THE AGENT. BY ACCESSING OR USING THE AGENT, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS SET FORTH BELOW.**

**Electronic Delivery of Documents**  
   
By agreeing to this Agreement, you agree that you accept electronic delivery of the following documents, and that you have carefully reviewed and agree to the terms of each and will retain copies for your records:

- [**Form CRS (Customer Relationship Summary)**](https://cdn.robinhood.com/assets/robinhood/legal/RHF%20Customer%20Relationship%20Summary.pdf)  
- [**RHF-RHS Customer Agreement**](https://cdn.robinhood.com/assets/robinhood/legal/Robinhood-Customer-Agreement.pdf)  
- [**Robinhood Margin Account Agreement**](https://cdn.robinhood.com/assets/robinhood/legal/RHS%20Customer%20Margin%20Account%20Agreement.pdf)  
- [**Robinhood Terms and Conditions**](https://cdn.robinhood.com/assets/robinhood/legal/Robinhood%20Terms%20and%20Conditions.pdf)  
- [**RHF Use and Risk Disclosures, RHF Business Continuity Plan Summary, and FINRA Public Disclosure Program**](https://cdn.robinhood.com/assets/robinhood/legal/RHF%20and%20RHS%20Business%20Continuity%20Plan%20Summary.pdf)  
- [**Robinhood User Privacy Statement**](https://robinhood.com/us/en/support/articles/privacy-policy/)  
- [**Robinhood Personnel Privacy Notice**](https://drive.google.com/file/d/1xKwVkquE0tv5PVk6uX97STsUxlws4_3d/view)   
- [**Robinhood Financial Privacy Notice**](https://cdn.robinhood.com/assets/robinhood/legal/Financial%20Privacy%20Notice.pdf)  
- [**Extended Hours Trading Disclosure**](https://cdn.robinhood.com/assets/robinhood/legal/ExtendedHoursTradingDisclosure.pdf)


You also consent to electronic delivery of trade confirmations, account statements, notices, and other disclosures relating to your agentic account and the Agent, including any generated by the Agent's automated activity when you are not viewing the app.

**1. Real Account, Real Money**

This is not a simulation or paper-trading environment. The Agent operates in a live agentic trading account and can execute real transactions using real funds and real securities in that account. Any gains, losses, fees, and tax consequences are real and are yours. You are solely responsible for funding the account and for all activity in it during testing. Do not deposit more than you are prepared to lose.

**2. Autonomous Activity and Trade Approvals**

The Agent can place trades and take other account actions without asking you to confirm each one. Specifically:

**Trade Approvals setting.** Your agentic account has a "Trade Approvals" safety setting. When Trade Approvals is ON, the Agent presents trades for your review and confirmation before they are submitted. When you turn Trade Approvals OFF, the Agent may submit trades on your account without any further review or confirmation by you. You are responsible for the state of this setting and for every trade placed while it is off.

**Availability during testing**. The Trade Approvals setting is still being built and may not be available, or may not function as described, for some or all of the testing period. During any period when it is unavailable or not fully functional, you may not be able to require the Agent to obtain your review and confirmation before it submits trades, and the Agent may place trades without that safeguard. The setting and its default behavior may also change without notice during testing. You should not rely on the availability or operation of Trade Approvals, and you remain responsible for all trades placed in your account, including any placed while the setting is unavailable, disabled, or not functioning as intended.

**Automations.** You can direct the Agent to create automations, which are asynchronous tasks that run on a schedule (as frequently as every minute) or in response to market conditions and that may place one or more trades each time they run, without prompting you. If the Trade Approvals setting is off, an automation can continue placing trades on its own until you pause or delete it. You are responsible for reviewing the logic of any automation you create and for monitoring its activity.

Pausing or deleting an automation, turning Trade Approvals on, or otherwise disabling the Agent will prevent it from submitting new instructions. It does not cancel, reverse, or unwind any order the Agent has already submitted to, and that has been received by, Robinhood; you remain bound by any such order, and Robinhood has no obligation to do so.

You acknowledge that autonomous and automated activity may produce trades you did not individually anticipate, at times you are not actively using the app, and that such trades are final and binding on your account.

**Information and disclosures you may not receive.** When you enable automated or autonomous trading (for example, by turning Trade Approvals off or by creating automations), the Agent may evaluate markets and place trades when you are not viewing the app or any screen. As a result, you may not see market data, quotes, disclosures, confirmations, or other information, whether or not its display or delivery is required by law, that you would normally see when placing a trade yourself. You acknowledge that:

- enabling automated or autonomous trading is your voluntary choice to have trades initiated and executed without contemporaneous display of, or your review of, any such information;  
- such information remains available to you through your account, trade confirmations, account statements, and other Robinhood channels;  
- you are responsible for obtaining and reviewing that information through those means; and  
- to the maximum extent permitted by applicable law, Robinhood is not responsible or liable for your not receiving or reviewing any such information as a result of your use of automated or autonomous trading, and your use of these features does not give rise to any claim based on the non-display, non-delivery, or non-receipt of such information.

You may turn off automated and autonomous trading at any time (by turning Trade Approvals on and pausing or deleting your automations) to restore the standard trade flow in which such information is displayed.

**3. Not Investment Advice**

**THE AGENT IS NOT AN INVESTMENT ADVISER AND DOES NOT PROVIDE INVESTMENT ADVICE, RECOMMENDATIONS, OR ENDORSEMENTS.**

All output, analysis, strategies, and trades generated or executed by the Agent are provided solely to let you test the product. You acknowledge and agree that:

- the Agent's output and actions do not constitute recommendations to buy, sell, or hold any security, cryptocurrency, or other asset, and do not constitute Robinhood endorsements of any strategy;  
- the Agent acts to carry out instructions and strategies that you configure and authorize;  
- you, not Robinhood, direct and are responsible for the strategy and the resulting trades;  
- you are solely responsible for determining the suitability of any particular security or investment strategy;  
- you are solely responsible for your own due diligence and for any investment decision reflected in your use of the Agent.

**4. Artificial Intelligence Limitations and Risks**

The Agent uses generative artificial intelligence, which has inherent limitations and risks. You acknowledge and agree that:

**Accuracy Not Guaranteed:** The Agent's output may contain errors, inaccuracies, omissions, or outdated information, and the Agent may misinterpret your prompts; generate erroneous, fabricated, or unintended output; experience latency, disconnection, or other malfunction; and otherwise behave in ways you did not intend or anticipate. Robinhood does not warrant the accuracy, completeness, reliability, or suitability of any output or action.

**Unpredictability:** AI-driven behavior may be unpredictable and may not meet your expectations, particularly in a pre-release product. This risk is greater when the Agent is permitted to act autonomously (see Section 2).

**Your Responsibility to Verify and Monitor:** You are responsible for monitoring the Agent's activity, reviewing your account, and verifying information before relying on it.

**5. Your Personal-Trading and Regulatory Obligations**

You are participating in this program as a Robinhood employee. You are hereby notified that your use of the Agent in your capacity as a Robinhood employee, including all prompts, outputs, and account activity, may be monitored by Robinhood for compliance, legal, and product purposes, as described in Section 9. This notice is provided in accordance with applicable employment law, including California Labor Code § 980 et seq. and any analogous laws in your jurisdiction. You represent that your use of the Agent, and any resulting orders or positions, will comply with all Robinhood employee policies governing personal trading and conduct, including the Code of Ethics and any pre-clearance, reporting, holding-period, restricted- or watch-list, blackout, outside-account, and compliance-system requirements that apply to you. If you are an associated person of a FINRA member, a person associated with a registered investment adviser, or are otherwise subject to employer, regulatory, or institutional policies governing your personal trading or use of automated trading tools, your use of the Agent must comply with those policies as well. You are solely responsible for configuring the Agent, including its settings, automations, and the strategies you authorize, so that its activity satisfies these obligations, including activity the Agent takes autonomously. Your participation in this program does not relieve you of, or shift to Robinhood, any of your personal compliance obligations. Robinhood has no obligation to build, apply, or enforce these policies through the Agent or as part of this testing program, and is not responsible for any violation arising from your use of the Agent. Nothing in this Agreement limits any compliance monitoring or surveillance Robinhood otherwise conducts with respect to employee personal trading.

**6. Compliance with Law; No Manipulative Trading**

You are solely responsible for ensuring that all activity conducted in your account through the Agent complies with applicable law, including prohibitions on market manipulation, spoofing, layering, wash trading, marking the close, and other manipulative or disruptive trading practices under the federal securities laws and the rules of FINRA and any applicable exchange or self-regulatory organization. You acknowledge that orders and trading patterns generated by the Agent, including any activity it takes autonomously or without your contemporaneous review, may give rise to such conduct, and you assume full responsibility for that activity regardless of whether you intended it.

**7. Memory, Skills, and Marketplace**

**Memory:** The Agent retains memory derived from your account, holdings, and prior interactions in order to personalize its behavior. This memory influences the Agent's future output and actions. Memory data is stored on both Robinhood systems and the LLM Provider systems. Upon conclusion of the testing program, memory data will be retained according to the relevant retention schedule (information collected in your capacity as a customer will be retained as outlined the customer records retention schedule for information collected in your capacity as an employee will be retained as outlined in the RHM Records Management Policy). You may request to view or correct the memory the Agent has stored about you by interacting with the Agent and requesting that it display and/or correct its memory file. 

**Skills and tools:** The Agent comes pre-loaded with skills and tools and may have access to Robinhood data and functionality across your profile. The Agent's ability to trade is limited to your agentic trading account(s).

**Marketplace / third-party skill packs:** If you add third-party skill packs during testing, those packs may add data sources, tools, or instructions that affect the Agent's behavior. Only skill packs that have been pre-approved by Robinhood may be installed during the testing period. Unapproved skill packs may expose your account data to unauthorized third parties, and installation of unapproved packs is prohibited. Third-party skill packs go through an approval process with Robinhood, but the content the third-party provides is not independently verified by Robinhood, and any test subscriptions are subject to their own terms.

**8. Margin**

If you open your agentic account as a margin (including limited margin) account, trading on margin involves additional risk, including the potential to lose more than your initial investment, and is subject to the terms of your margin account agreement. Please read carefully the [Margin Account Agreement](https://cdn.robinhood.com/assets/robinhood/legal/RHS%20Customer%20Margin%20Account%20Agreement.pdf) and the [Margin Disclosure Statement](https://cdn.robinhood.com/assets/robinhood/legal/RHF%20and%20RHS%20Margin%20Disclosure%20Statement.pdf).

**9. Privacy and Data**

All interactions with the Agent, including your prompts, the Agent's output, its memory, and the actions it takes, are logged and retained by Robinhood for compliance monitoring, quality assurance, debugging, and product improvement of the Agent testing program. Robinhood will not use testing interaction data for commercial profiling of you as a customer without your separate consent. Your use of the Agent as a customer is subject to Robinhood's [User Privacy Statement](https://robinhood.com/us/en/support/articles/privacy-policy/) and your applicable customer agreements. Robinhood applies reasonable technical and organizational security measures to testing data. Robinhood collects and retains testing data only to the extent necessary for the purposes described in this Agreement.  

The Agent is powered by a large language model operated by Anthropic (the "LLM Provider"), not by Robinhood (the LLM Provider is subject to change as we develop and improve the product; we will notify you if we use a different LLM provider for employee testing). To generate the Agent's output, your prompts and the following categories of account and profile data are transmitted to and processed by the LLM Provider on its own systems, outside Robinhood's environment: 

**Account & Portfolio**

- Brokerage account list (type, account number, default status, agent-trading eligibility)  
- Real-time buying power  
- Portfolio snapshot (total value, daily P\&L, withdrawable cash)  
- Ticker/instrument ID lookup by company name

**Equities**

- Live stock quotes and prior session close prices  
- Per-symbol tradability status (session eligibility, halt status)  
- Open positions (shares held, average cost basis, shares available to sell)  
- Order history (status, fills, cancellations)  
- Pre-trade order simulation results and alerts  
- Order placement and cancellation

**Options**

- Option chains (expiration dates, settlement type, contract multiplier)  
- Contract details (strike, type, expiration, active status)  
- Live option quotes and prior session close prices  
- Open options positions and cost basis  
- Options order history, simulation, placement, and cancellation

**Scanner / Screener**

- Saved screener list (filters, sort order, AI-managed flag)  
- Live screener results against current market data  
- Screener creation, filter updates, and sort configuration

**Watchlists**

- Watchlist inventory (custom and Robinhood-curated)  
- Watchlist contents (tickers, asset types)  
- Watchlist creation, renaming, and symbol add/remove  
- Robinhood curated list discovery, follow, and unfollow status

The LLM Provider processes this data as a data processor under a Data Processing Agreement ("DPA") with Robinhood. The DPA prohibits the LLM Provider from using your data to train its models or for any purpose other than providing the Agent services to Robinhood, and requires the LLM Provider to maintain appropriate security safeguards. Robinhood operates the Agent and logs and retains your interactions as described above in Section 7, but Robinhood does not control the LLM Provider or how it processes data on its own systems. Any context that you provide to the Agent, including but not limited to any prompts you send to your agent, tool call responses, and LLM responses, may be shared with the LLM Provider and will be deleted from the LLM Provider's systems according to the terms of the DPA.  

**10. Disclaimers**

**TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE AGENT IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, AND NON-INFRINGEMENT. ROBINHOOD DOES NOT WARRANT THAT THE AGENT WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE, OR THAT ITS OUTPUT OR ACTIONS WILL MEET YOUR REQUIREMENTS. ALL DISCLAIMERS AND LIMITATIONS IN THIS AGREEMENT APPLY WITH EVEN GREATER FORCE TO THIS PRE-RELEASE TESTING VERSION.**

**11. Limitation of Liability**

**TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ROBINHOOD SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES ARISING OUT OF OR RELATING TO YOUR USE OF THE AGENT, INCLUDING LOSS OF PROFITS, LOSS OF DATA, OR INVESTMENT LOSSES, EVEN IF ROBINHOOD HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.**

Your sole remedy for dissatisfaction with the Agent is to stop using it, unless another remedy is made available to you under the RHF-RHS Customer Agreement.

**12. Governing Agreements; Modifications; Disputes**

This Agreement supplements and is incorporated into your existing customer agreements with Robinhood entities (including any agentic account, margin, and crypto agreements). In the event of any conflict between this Agreement and your other customer agreements, the terms of your other customer agreements control. Robinhood may modify this Agreement at any time and will notify you of material changes. Any dispute arising from or relating to this Agreement or your use of the Agent is subject to the dispute resolution and arbitration provision in Section 39 of your [RHF-RHS Customer Agreement](https://cdn.robinhood.com/assets/robinhood/legal/Robinhood-Customer-Agreement.pdf).

**13. Notices**

**How Robinhood gives you notice**. You agree that Robinhood may provide any notice, disclosure, or other communication relating to this Agreement, your agentic account, or the Agent electronically, including by posting in the Robinhood app, by email to the address associated with your account, by in-app message, or by push notification. Any such communication is considered given to and received by you when Robinhood sends or posts it, whether or not you actually access it. This Section supplements the 'Electronic Delivery of Documents' section above.

**Keeping your information current; your responsibility to monitor**. You agree to keep the contact information associated with your account accurate and current. Because the Agent can act autonomously when you are not viewing the app, you remain responsible for monitoring the Robinhood app and the email address associated with your account, and for reviewing notices delivered electronically, even during periods when you are not actively using the Agent.

**Relationship to other agreements**. This Section supplements the notice and electronic delivery provisions of your RHF-RHS Customer Agreement. In the event of any conflict regarding notices relating to your account, Section 12 governs.

**14. Complaints**

Do not use the Agent's chat or prompt interface to submit formal complaints, regulatory feedback, or other compliance-related concerns. The Agent is an automated tool; it does not log, route, or escalate complaints, and your prompts are not monitored for that purpose. To ensure your issue is properly recorded and addressed, submit any complaint or concern through Robinhood's designated support and complaint channels. Report testing-related bugs and product feedback through the designated internal testing channels described above.

**15. Preservation of Customer and Employee Rights**

Your participation in this employee testing program does not waive, limit, or affect any rights you have as a customer or as an employee under your Robinhood customer or employment agreements. This Agreement supplements but does not supersede those agreements. Notwithstanding Section 12, with respect to your rights as an employee, in the event of any conflict the terms most favorable to you control. You retain all rights, remedies, and protections available to you as a Robinhood customer and employee, including all dispute resolution and complaint procedures.

**16. Acknowledgment and Acceptance**

**By using the Agent, you acknowledge that:** 

- You have read, understood, and agree to be bound by this Agreement;  
- You understand the Agent uses artificial intelligence and may generate inaccurate output or take unintended actions;  
- You understand the Agent operates on a real account with real money, and that it can place real trades autonomously, including without confirming each trade, when you turn Trade Approvals off or create automations;  
- You are responsible for monitoring your account and the Agent's activity, and you accept all risks associated with testing the Agent.

**Tester Acknowledgment**

By tapping or clicking "Accept" below, you (1) apply to open an agentic trading account, (2) agree to this Agreement and to the documents listed under Electronic Delivery above, and (3) adopt this action as your electronic signature. You understand that you are entering into binding legal agreements**.**