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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By using one of these tools, you agree that Public.com may transfer that information to the applicable third party service.
We will disclose information to third parties about your account or the transfers you make: (i) where it is necessary for completing transfers, or (ii) in order to verify the existence and condition of your account...
We may also use IP address or other device identifiers to identify individuals, either acting alone or in cooperation with third parties such as copyright owners, internet service providers...
"our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Notice, and we may use and disclose it to others for any purpose, without limitation.Excerpt from Affirm's 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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The clause states: “our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Notice, and we may use and disclose it to others for any purpose, without limitation.”
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