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
Acceptance of the Notice combined with use of the Services is treated as consent to third-party merchant marketing data disclosure, meaning continued use triggers this consent.
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 →By accepting Affirm's Notice and using its Services, you consent to your information being shared with merchants you interact with for their marketing purposes.
How other platforms handle this
disclosure is required by a third-party to complete a transaction initiated by the user
If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above...
Under Section 1798.83, Ancestry currently does not share any Personal Information with third parties for their own direct marketing purposes.
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"When you accept this Notice and use our Services, you consent to us disclosing your information to merchants you interact with for those merchants to market to you.— Excerpt from Affirm's Affirm Privacy Policy
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Acceptance of the Notice combined with use of the Services is treated as consent to third-party merchant marketing data disclosure, meaning continued use triggers this consent.
By accepting Affirm's Notice and using its Services, you consent to your information being shared with merchants you interact with for their marketing purposes.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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