Under the federal Gramm-Leach-Bliley Act, Affirm must tell you how it handles your financial data and give you the right to opt out of some, but not all, types of financial data sharing.
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
GLBA opt-out rights are narrower than many consumers expect: they apply to sharing with non-affiliated third parties for marketing but do not cover sharing for joint marketing arrangements or operational service providers.
Interpretive note: The policy does not enumerate with specificity which sharing categories are subject to GLBA opt-out versus which fall within exempt categories, creating uncertainty for consumers trying to understand the practical scope of their opt-out rights.
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 →You have a federal right to opt out of certain sharing of your financial information with non-affiliated third parties, but this right does not cover all sharing; Affirm may still share your data with joint marketing partners and service providers without your opt-out being effective.
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"We are required by federal law to give you important information about how we collect, share, and protect your personal financial information. Federal law gives you the right to limit some but not all sharing of your personal financial information.Excerpt from Affirm's Privacy Policy
REGULATORY LANDSCAPE: The Gramm-Leach-Bliley Act financial privacy rules, implemented by CFPB Regulation P, require annual privacy notices and opt-out rights for sharing with non-affiliated third parties outside specified exceptions.
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GLBA opt-out rights are narrower than many consumers expect: they apply to sharing with non-affiliated third parties for marketing but do not cover sharing for joint marketing arrangements or operational service providers.
You have a federal right to opt out of certain sharing of your financial information with non-affiliated third parties, but this right does not cover all sharing; Affirm may still share your data with joint marketing partners and service providers without your opt-out being effective.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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