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
This provision establishes the operational framework for marketing-related data sharing across Affirm's affiliate network and external marketing partners within regulatory bounds. The provision's significance lies in defining the scope of permissible sharing and identifying that opt-out mechanisms may be available for specified sharing categories.
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 →Under this clause, personal information may be shared with both affiliated entities and unaffiliated third parties for joint marketing activities. The terms indicate that opt-out rights may apply to certain sharing categories, though the specific types of information subject to opt-out and the mechanics of exercising opt-out are not detailed in this clause.
How other platforms handle this
We may collect information derived or resulting from voluntary surveys. We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our "Contact Us" form.
For joint marketing with other financial companies - To offer our products and services to you. Our joint marketing partners include our banking partner, nbkc bank, and other financial services companies.
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
Monitoring
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"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
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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This provision establishes the operational framework for marketing-related data sharing across Affirm's affiliate network and external marketing partners within regulatory bounds. The provision's significance lies in defining the scope of permissible sharing and identifying that opt-out mechanisms may be available for specified sharing categories.
Under this clause, personal information may be shared with both affiliated entities and unaffiliated third parties for joint marketing activities. The terms indicate that opt-out rights may apply to certain sharing categories, though the specific types of information subject to opt-out and the mechanics of exercising opt-out are not detailed in this clause.
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