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
If these activities constitute a CCPA sale or sharing, California residents may have rights to opt out of them, making this disclosure legally significant.
Interpretive note: The clause uses 'may be considered,' indicating legal uncertainty about whether the activity definitively qualifies as a CCPA sale or sharing. The canonical claim preserves this qualifier.
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 →Affirm's behavioral advertising partnerships may trigger your CCPA rights regarding the sale or sharing of your Personal Information.
How other platforms handle this
Faire reserves the right to report any activity occurring on or related to the Services to relevant regulatory authorities as required under applicable law.
(ii) disclosure (by text, link, icon, or otherwise) regarding Influencer's participation in the Amazon Influencer Program.
Service Tiers described as "no ads" or "ad-free" are generally free of commercial interruptions, with certain exceptions...including where: (i) streaming rights or other limitations require certain Content to play with ads...
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"Affirm does work with advertising partners to collect information about user internet browsing activities to provide those users with more relevant advertising as they browse. This may be considered the "sale" or "sharing" of Personal Information for cross-context behavioral advertising under the CCPA.— Excerpt from Affirm's Affirm Privacy Policy
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If these activities constitute a CCPA sale or sharing, California residents may have rights to opt out of them, making this disclosure legally significant.
Affirm's behavioral advertising partnerships may trigger your CCPA rights regarding the sale or sharing of your Personal Information.
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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