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.
View change record →How other platforms handle this
telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.
We may attempt to verify your employment history or status through various methods, including third-party integrations or services. We may also utilize signals we may receive from your current or former employer.
Partners who have implemented or integrated certain Instacart services on their websites or applications may also let us collect information about your use of their sites or applications or share such information with us.
"We may collect information about your physical or biological characteristics such as photographs. These photographs may be used by our identity verification vendors for verifying your identity or detecting fraud (including through facial recognition technologies...Excerpt from Affirm's Privacy Policy
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The clause states: “We may collect information about your physical or biological characteristics such as photographs. These photographs may be used by our identity verification vendors for verifying your identity or detecting fraud (including through facial recognition technologies...”
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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