Affirm · Affirm Privacy Policy · View original document ↗

Device and Geolocation Tracking

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Affirm collects technical information about your device and, where you permit it, your precise physical location when you use its app or website.

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)

Device identifiers and geolocation data can be used for behavioral tracking and advertising targeting purposes beyond the basic function of processing a loan.

Interpretive note: The policy states geolocation is collected 'with your permission' but does not specify whether this is an in-app consent or device-level permission, and the downstream uses of location data beyond fraud prevention are not fully enumerated.

Consumer impact (what this means for users)

Affirm may collect your device identifiers and precise location data, which can contribute to behavioral profiling and advertising targeting in addition to fraud prevention and service delivery.

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
    Visit Affirm's privacy portal to submit a request to limit use of sensitive personal information including geolocation data, as available to California residents under CPRA.

How other platforms handle this

DoorDash Medium

Geolocation Information, if you have consented by enabling location access, we may receive and store your precise location information, including when our apps are running in the foreground (our app is open and on screen) or background (our app is open, not on screen) of your device. You may use our...

Robinhood Medium

Geolocation data, such as device location. Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement. Device identifiers, such as IP address, unique d...

Zendesk Medium

We use cookies and similar tracking technologies to track the activity on our websites and services and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze our services. You can instruct your browser to ...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may collect information about the device you use to access our services, including your device type, operating system, browser type, IP address, and device identifiers. We may also collect precise geolocation information with your permission.

— Excerpt from Affirm's Affirm Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Collection of precise geolocation data engages CCPA's sensitive personal information category under CPRA, which grants California residents the right to limit the use and disclosure of sensitive data. FTC Act Section 5 applies to the adequacy of consent mechanisms for location collection. State-level mobile privacy statutes in some jurisdictions may impose additional notice or consent requirements for location tracking. GOVERNANCE EXPOSURE: Medium. Precise geolocation is classified as sensitive personal information under CPRA, requiring a specific 'limit use' opt-out mechanism separate from general CCPA opt-outs. If the policy does not provide a clearly accessible sensitive data limitation right, CPRA compliance exposure exists. JURISDICTION FLAGS: California CPRA sensitive personal information provisions require a 'Limit the Use of My Sensitive Personal Information' link or equivalent. Illinois and other states with specific location privacy protections may impose additional requirements. If location data is shared with marketing partners, CCPA sharing opt-out requirements apply. CONTRACT AND VENDOR IMPLICATIONS: Analytics and advertising SDK vendors embedded in the Affirm mobile application should be assessed to determine whether they independently collect device or location data, which could trigger separate disclosure and consent obligations. Third-party advertising partners receiving device identifiers should operate under data processing agreements. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the app-level permission request for location is accompanied by adequate disclosure of how location data is used, that CPRA's sensitive data limitation right is implemented, and that device identifier data shared with advertising networks is addressed in the policy's disclosure of data sharing categories.

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 the adequacy of consent and disclosure practices for geolocation data collection by consumer-facing apps
    File a complaint →
  • State AG
    California Privacy Protection Agency and AG enforce CPRA sensitive personal information requirements applicable to precise geolocation data
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
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-008403
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-008403
Captured: 2026-05-07 19:04:44 UTC
SHA-256: 14612e5d4e154bb0…
URL: https://conductatlas.com/platform/affirm/affirm-privacy-policy/device-and-geolocation-tracking/
Accessed: May 13, 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 Device and Geolocation Tracking clause do?

Device identifiers and geolocation data can be used for behavioral tracking and advertising targeting purposes beyond the basic function of processing a loan.

How does this clause affect you?

Affirm may collect your device identifiers and precise location data, which can contribute to behavioral profiling and advertising targeting in addition to fraud prevention and service delivery.

Is ConductAtlas affiliated with Affirm?

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