Affirm uses your transaction history, browsing behavior, and other data to build a profile of your preferences and interests, which it then uses to personalize offers and make business decisions.
This analysis describes what Affirm's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Behavioral profiling means Affirm uses your financial activity to make inferences about you that go beyond your loan transactions, which can affect what products you are shown and potentially how you are assessed.
Interpretive note: The phrase 'other business purposes' for use of inferences is not specifically defined, creating ambiguity about the full scope of profiling applications.
The updated Privacy Policy establishes that Affirm qualifies as a financial institution under the Gramm-Leach-Bliley Act, meaning personal information collected in connection with Affirm services is governed by federal banking law rather than applicable state privacy laws. The policy now explicitly discloses collection of identity and profile information including full name, date of birth, Social Security number, email, mailing address, phone number, and password. The updated terms also disclose new data sharing arrangements with fraud prevention, identity verification, and risk intelligence providers, which were not previously detailed. You can contact Affirm's privacy team using the phone number provided in the updated policy to exercise data privacy rights.
View change record →Affirm may draw inferences about your personal characteristics from your financial and behavioral data, and these inferences can be used for marketing personalization and other business purposes beyond servicing your loan.
How other platforms handle this
We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"We may use the information we collect to draw inferences about your preferences, interests, and characteristics. We may use these inferences to personalize your experience, provide you with relevant offers, and for other business purposes.— Excerpt from Affirm's Affirm Privacy Policy
REGULATORY LANDSCAPE: CCPA and CPRA classify inferences drawn from personal information to create consumer profiles as a category of personal information subject to access and deletion rights, enforced by the California Privacy Protection Agency. FTC Act Section 5 applies to the fairness and transparency of profiling disclosures. If inferences are used in credit eligibility decisions, FCRA adverse action and Equal Credit Opportunity Act requirements enforced by CFPB may also be implicated. GOVERNANCE EXPOSURE: Medium. The use of behavioral inferences for both personalization and unspecified 'other business purposes' creates ambiguity about the full scope of profiling use cases, which may create disclosure adequacy issues under CCPA and CPRA. JURISDICTION FLAGS: California residents have CPRA rights to access and correct inferences held about them as a category of personal information. States with comprehensive privacy laws including Colorado, Connecticut, and Virginia include profiling opt-out rights in automated decision-making contexts. If inferences affect credit decisions, federal ECOA and FCRA requirements apply nationally. CONTRACT AND VENDOR IMPLICATIONS: Any third-party analytics or profiling vendors involved in generating inferences should be reviewed to ensure they operate under data processing agreements that restrict onward use and provide adequate security. If inference data is shared with marketing partners, downstream use restrictions should be contractually specified. COMPLIANCE CONSIDERATIONS: Compliance teams should document the inference categories generated, review whether any inferences are used in credit or eligibility decisions triggering FCRA or ECOA requirements, and ensure that CCPA-required disclosures of inference categories are included in the policy's data inventory.
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Behavioral profiling means Affirm uses your financial activity to make inferences about you that go beyond your loan transactions, which can affect what products you are shown and potentially how you are assessed.
Affirm may draw inferences about your personal characteristics from your financial and behavioral data, and these inferences can be used for marketing personalization and other business purposes beyond servicing your loan.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Affirm.