Affirm may share your personal and financial information with the retailers you shop at through Affirm and with marketing companies so those parties can send you promotional offers.
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 clause means your lending relationship with Affirm can result in your data being used for advertising and marketing by third parties beyond what is necessary to process your loan.
Interpretive note: The specific categories of data shared with each type of marketing or merchant partner, and whether opt-out mechanisms satisfy both GLBA and CCPA requirements in practice, require further operational review.
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 →Your financial and behavioral data may be shared with retailers and marketing partners for advertising purposes, which could result in targeted promotions based on your Affirm loan and purchase history.
How other platforms handle this
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Any such de-identified genetic information and phenotypic information we share with third parties for research purposes is done in accordance with Part 46 (beginning with Section 46.101) of Title 45 of the Code of Federal Regulations.
"We may share your personal information with our merchant and business partners, marketing partners, and other third parties for purposes such as joint marketing, cross-marketing, and to provide you with offers and promotions that may be of interest to you.Excerpt from Affirm's Privacy Policy
REGULATORY LANDSCAPE: GLBA requires Affirm to provide opt-out rights before sharing non-public personal information with non-affiliated third parties for marketing purposes; the adequacy of the opt-out mechanism and notice is subject to CFPB and FTC …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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This clause means your lending relationship with Affirm can result in your data being used for advertising and marketing by third parties beyond what is necessary to process your loan.
Your financial and behavioral data may be shared with retailers and marketing partners for advertising purposes, which could result in targeted promotions based on your Affirm loan and purchase history.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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