Affirm may share your personal and financial information with the retailers you shop at through Affirm and with marketing companies so those parties can send you promotional offers.
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
This clause means your lending relationship with Affirm can result in your data being used for advertising and marketing by third parties beyond what is necessary to process your loan.
Interpretive note: The specific categories of data shared with each type of marketing or merchant partner, and whether opt-out mechanisms satisfy both GLBA and CCPA requirements in practice, require further operational review.
Your financial and behavioral data may be shared with retailers and marketing partners for advertising purposes, which could result in targeted promotions based on your Affirm loan and purchase history.
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"We may share your personal information with our merchant and business partners, marketing partners, and other third parties for purposes such as joint marketing, cross-marketing, and to provide you with offers and promotions that may be of interest to you.— Excerpt from Affirm's Affirm Privacy Policy
REGULATORY LANDSCAPE: GLBA requires Affirm to provide opt-out rights before sharing non-public personal information with non-affiliated third parties for marketing purposes; the adequacy of the opt-out mechanism and notice is subject to CFPB and FTC review. CCPA and CPRA treat sharing of personal information for cross-context behavioral advertising as a 'share' triggering opt-out rights under CPRA amendments enforced by the California Privacy Protection Agency. FTC Act Section 5 applies to the clarity and placement of opt-out disclosures. GOVERNANCE EXPOSURE: Medium. The breadth of marketing sharing authorized, including joint marketing and cross-marketing with merchant and business partners, creates GLBA opt-out compliance exposure and CCPA sharing opt-out implementation requirements. If the opt-out mechanism is not prominently disclosed and operationally accessible, regulatory exposure is heightened. JURISDICTION FLAGS: California residents have a statutory right to opt out of sharing for cross-context behavioral advertising under CPRA. GLBA opt-out requirements apply nationally. Colorado, Virginia, Connecticut, and other states with comprehensive privacy laws may have analogous opt-out rights for targeted advertising that should be evaluated. CONTRACT AND VENDOR IMPLICATIONS: Marketing partner agreements should include contractual restrictions on downstream use of shared data, consistent with GLBA's contractual safeguards requirement for non-affiliated third-party sharing. Merchant partner agreements should define the scope of permissible data use and include data security obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that GLBA opt-out notices are delivered at account opening and renewed as required, that CCPA opt-out of sharing mechanisms are implemented and functional, and that marketing partner contracts include the required downstream use limitations and data protection standards.
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This clause means your lending relationship with Affirm can result in your data being used for advertising and marketing by third parties beyond what is necessary to process your loan.
Your financial and behavioral data may be shared with retailers and marketing partners for advertising purposes, which could result in targeted promotions based on your Affirm loan and purchase history.
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