Affirm · Affirm Privacy Policy · View original document ↗

GLBA Affiliate and Non-Affiliate Sharing for Marketing

Medium severity Unique · 0 of 325 platforms
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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)

Under GLBA, non-affiliate sharing for marketing requires you to be given a chance to opt out — if you don't act, your financial data may be used for marketing purposes by companies you've never heard of.

Consumer impact (what this means for users)

Affirm's privacy policy authorizes collection of a wide range of data beyond basic loan information, including device identifiers, geolocation, browsing and purchase behavior, and inferences drawn from external data sources, which Affirm may use for its own marketing and share with merchant and advertising partners. This means your financial relationship with Affirm can generate a behavioral profile that extends into advertising and marketing contexts outside your direct lending transactions. You can submit a request to access, delete, or opt out of certain data sharing by visiting Affirm's privacy rights portal at https://www.affirm.com/privacy.

How other platforms handle this

LinkedIn Medium

Affiliates are companies controlling, controlled by or under common control with us, including, for example, LinkedIn Ireland, LinkedIn Corporation, LinkedIn Singapore and Microsoft Corporation or any of its subsidiaries (e.g., Github, Inc.).

Mercury Medium

We may share your personal information with third parties, including our affiliates, service providers, financial institution partners, and business partners. We may share information with third parties for their own marketing purposes or to provide you with offers and promotions that may be of inte...

OpenAI Medium

We may share your Personal Data with third parties in the following circumstances: Vendors and Service Providers: We share your Personal Data with vendors and service providers who perform services for us, such as hosting, infrastructure, analytics, payment processing, and customer support. Affiliat...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your personal information with our affiliates and non-affiliated third parties for joint marketing purposes as permitted under the Gramm-Leach-Bliley Act. You may have the right to opt out of certain types of information sharing.

— Excerpt from Affirm's Affirm Privacy Policy

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
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-005381
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-005381
Captured: 2026-05-07 19:04:44 UTC
SHA-256: 14612e5d4e154bb0…
URL: https://conductatlas.com/platform/affirm/affirm-privacy-policy/glba-affiliate-and-non-affiliate-sharing-for-marketing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Affirm's GLBA Affiliate and Non-Affiliate Sharing for Marketing clause do?

Under GLBA, non-affiliate sharing for marketing requires you to be given a chance to opt out — if you don't act, your financial data may be used for marketing purposes by companies you've never heard of.

Is ConductAtlas affiliated with Affirm?

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