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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California residents have the right to request certain information regarding our disclosure of personal information...to third parties for their direct marketing purposes unless we provide them with an ability to exercise choice regarding such disclosures.
to object to profiling activities based on our own legitimate interests
You also have the right to object to the processing of Service Data or to export Service Data to another service.
"Your information may also be used to operate sweepstakes, contests, referral programs, or other optional promotional offers. Participation is voluntary and you may opt out at any time.Excerpt from Affirm's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The clause states: “Your information may also be used to operate sweepstakes, contests, referral programs, or other optional promotional offers. Participation is voluntary and you may opt out at any time.”
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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