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
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.
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We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
We generally retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements...
We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice...but no longer than as required or permitted under applicable law or internal Walmart policy.
"Affirm will retain your Personal Information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law.Excerpt from Affirm's Privacy Policy
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The clause states: “Affirm will retain your Personal Information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law.”
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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