Provision record
Affirm · Affirm Privacy Policy · View original document ↗

Collection of Data from Third-Party Sources

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Affirm obtains information about you not just from your direct interactions with its app or website, but also from credit bureaus, data brokers, and its retail merchant partners.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This means your profile at Affirm is built from sources you may not be aware of or have directly consented to, which can affect credit decisions and how you are targeted for marketing.

Interpretive note: The exact categories of data obtained from data brokers and the specific purposes for which they are used are not fully enumerated, creating some uncertainty about the scope of this collection.

Recent Activity

This document changed recently

Medium Jun 3, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Your data profile at Affirm may include information from data brokers and credit bureaus combined with merchant transaction data, creating a more comprehensive record than you may expect from a loan provider.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Visit Affirm's privacy portal and submit a data access request to see what categories of personal information have been collected about you, including from third-party sources.

How other platforms handle this

Glassdoor Medium

We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We may collect information about you from third parties, such as credit bureaus, identity verification services, data brokers, and our merchant and business partners. This information may include your credit history, identity verification information, and other information about you.

Excerpt from Affirm's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Collection of credit bureau data triggers Fair Credit Reporting Act permissible purpose requirements enforced by the CFPB and FTC; any use of consumer report data for eligibility, marketing, or profiling purposes must satisfy …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →
  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
TCPA
United States Federal
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Affirm Privacy Policy
Entity
Affirm
Document last updated
March 24, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-008400
Document ID
CA-D-00168
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
14612e5d4e154bb0a5181a10837054a0e2bd38f2d20df5efbd7e3d764f0cae52
Analysis generated
May 7, 2026 19:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Affirm
Document: Affirm Privacy Policy
Record ID: CA-P-008400
Captured: 2026-05-07 19:04:44 UTC
SHA-256: 14612e5d4e154bb0…
URL: https://conductatlas.com/platform/affirm/affirm-privacy-policy/provision/CA-P-008400/collection-of-data-from-third-party-sources/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Affirm's Collection of Data from Third-Party Sources clause do?

This means your profile at Affirm is built from sources you may not be aware of or have directly consented to, which can affect credit decisions and how you are targeted for marketing.

How does this clause affect you?

Your data profile at Affirm may include information from data brokers and credit bureaus combined with merchant transaction data, creating a more comprehensive record than you may expect from a loan provider.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Affirm?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Affirm.