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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These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.
We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.
We also require these service providers to protect your personal information to at least the same standards that we do.
"To service providers and contractors to perform functions on our behalf, such as processing transactions, marketing, billing and collection, auditing and accounting, professional services, measurement and analytics services, security...Excerpt from Affirm's Privacy Policy
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The clause states: “To service providers and contractors to perform functions on our behalf, such as processing transactions, marketing, billing and collection, auditing and accounting, professional services, measurement and analytics services, security...”
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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