Affirm · Affirm Privacy Policy · View original document ↗

Data Retention

Low severity Medium confidence Explicitdocumentlanguage Common · 136 of 343 platforms
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Recent governance activity Affirm recorded 3 documented changes in the last 30 days.
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Document Record

What it is

Affirm keeps your personal data for as long as it needs to run its services and meet legal requirements, with no specific deletion timeline stated for most data categories.

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)

An open-ended retention standard without specific timelines means your financial and behavioral data may be retained indefinitely unless you affirmatively request deletion.

Interpretive note: The policy does not provide category-specific retention timelines; it is unclear whether Affirm's operational retention schedules satisfy CPRA's disclosure specificity requirement.

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 →

Consumer impact (what this means for users)

Affirm does not commit to specific retention periods for most personal data categories, meaning your loan history, behavioral inferences, and other profile data may be held for an extended or indeterminate period unless you exercise deletion rights.

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.
  • Delete Your Data
    Submit a data deletion request through Affirm's privacy portal at affirm.com/privacy if you want your personal information removed after you stop using Affirm's services.

How other platforms handle this

Grindr Medium

We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.

Threads Medium

We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.

Hinge Medium

After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.

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▸ View Original Clause Language DOCUMENT RECORD
"
We retain your personal information for as long as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period for specific types of personal information may vary based on the nature of the information and our legal requirements.

— Excerpt from Affirm's Affirm Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: GLBA safeguards rules require data disposal procedures for customer financial information. CCPA and CPRA require that retention periods be disclosed in the privacy policy for each category of personal information; a policy that states only a general necessity standard without category-specific periods may not satisfy CPRA's disclosure specificity requirement. FTC Act Section 5 unfair practices standards apply to retention practices that create unnecessary consumer risk. GOVERNANCE EXPOSURE: Medium. CPRA regulations require that privacy policies disclose the retention period or criteria used to determine retention for each category of personal information. A generalized necessity standard without category-level disclosure may not satisfy this requirement, creating California regulatory exposure. JURISDICTION FLAGS: California CPRA retention disclosure requirements apply to all covered businesses. GLBA data disposal requirements apply nationally. If Affirm processes data subject to FCRA, consumer report retention rules impose specific time limits for certain record types. CONTRACT AND VENDOR IMPLICATIONS: Service provider and data processor agreements should include data retention and deletion schedules consistent with Affirm's stated retention policies and GLBA disposal requirements. Downstream deletion obligations should be contractually required upon termination of processing relationships. COMPLIANCE CONSIDERATIONS: Compliance teams should audit data retention schedules by category, assess whether CPRA's category-specific disclosure requirement is satisfied, document the legal basis for each retention period, and confirm that deletion requests under CCPA result in timely deletion from both Affirm systems and downstream processors.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    FTC Act Section 5 applies to data retention and disposal practices that may create unreasonable consumer risk, and FTC enforces GLBA data disposal requirements
    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-008406
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-008406
Captured: 2026-05-07 19:04:44 UTC
SHA-256: 14612e5d4e154bb0…
URL: https://conductatlas.com/platform/affirm/affirm-privacy-policy/data-retention/
Accessed: June 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

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Frequently Asked Questions

What does Affirm's Data Retention clause do?

An open-ended retention standard without specific timelines means your financial and behavioral data may be retained indefinitely unless you affirmatively request deletion.

How does this clause affect you?

Affirm does not commit to specific retention periods for most personal data categories, meaning your loan history, behavioral inferences, and other profile data may be held for an extended or indeterminate period unless you exercise deletion rights.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 136 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.