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 policy explicitly discloses that Affirm collects cart contents, product details, pricing, and page URLs when you use its browser extension or in-app browser to visit merchant websites. This represents a material expansion of the prior disclosure, which only mentioned collecting website domain. The policy states this information is used to provide and improve extension features, provide personalized experiences, and support related services. You can limit collection by disabling the extension in browser settings, uninstalling it, hiding it, or choosing not to use the in-app browser for merchant browsing where an alternative is available.
View change record →Affirm's behavioral advertising partnerships may trigger your CCPA rights regarding the sale or sharing of your Personal Information.
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Any content made public will be publicly accessible through the internet and may be crawled and indexed by search engines.
we may disclose Confidential Information and Company Data if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to: (i) comply with legal process, applicable laws or government requests...
Recipient may disclose Discloser's Confidential Information: (i) to the extent required by applicable law or regulation; (ii) pursuant to a subpoena or order of a court or regulatory, self-regulatory, or legislative body of competent jurisdiction.
"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 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 267 platforms. See the full comparison.
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