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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"We enforce physical access controls to our buildings and we authorize access to your information only for those employees or agents who require it to fulfill the responsibilities of their jobs.— Excerpt from Affirm's Affirm Privacy Policy
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The clause states: “We enforce physical access controls to our buildings and we authorize access to your information only for those employees or agents who require it to fulfill the responsibilities of their jobs.”
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