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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In limited circumstances, we may retain certain information for purposes including safety, security, fraud prevention, and compliance with our legal obligations.
We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
We store your personal information for a period of time that is consistent with the business purposes set forth in Section 3 of this policy or as long as needed to fulfill and comply with legal obligations.
"If you close your Affirm account, we will mark your account in our database as "Closed," but will keep your account information in our database to comply with our legal obligations.Excerpt from Affirm's Privacy Policy
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The clause states: “If you close your Affirm account, we will mark your account in our database as "Closed," but will keep your account information in our database to comply with our legal obligations.”
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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