Affirm · Affirm Terms of Service · View original document ↗

Data Sharing with Third Parties

Medium severity Medium confidence Explicitdocumentlanguage Rare · 6 of 325 platforms
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Document Record

What it is

By using Affirm, you authorize the company to share your personal information and transaction history with merchants, service providers, and other partners.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Your transaction data and personal information may be shared with the merchants where you shop using Affirm and with other third parties, which affects your privacy beyond the Affirm platform itself.

Interpretive note: The full scope of data sharing is determined by the Privacy Policy, which is a separate document; the terms of that document are not fully assessable from this terms of service alone.

Consumer impact (what this means for users)

This provision means that personal information, including your name, contact details, and purchase history, may be shared with merchants and third-party service providers, and the full scope of that sharing is governed by Affirm's separate Privacy Policy.

How other platforms handle this

Revolut Medium

When you ask us to open an Account, we or someone acting for us will ask for information about you and where the money you will put in your Account comes from. We do this for a number of reasons, including to check your credit score and identity, and to meet our legal and regulatory requirements. Ou...

Wise Medium

We may share your personal information with third parties, including service providers, financial institutions, regulatory authorities, and fraud prevention agencies, where necessary to provide our services, comply with legal obligations, or protect against fraud and financial crime.

Microsoft Medium

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We also share data with Microsoft-controlled affiliates and subsidiaries; with vendors or agents working on our behalf for the purposes described in this...

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▸ View Original Clause Language DOCUMENT RECORD
"
By using the Services, you authorize Affirm to share your information, including personal information and information related to your transactions and use of the Services, with merchants, service providers, and other third parties as further described in our Privacy Policy.

— Excerpt from Affirm's Affirm Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Data sharing practices in consumer financial services engage the Gramm-Leach-Bliley Act, which governs the sharing of nonpublic personal information by financial institutions and requires annual privacy notices and opt-out rights for certain data sharing. The FTC enforces GLBA privacy requirements for non-bank financial institutions such as Affirm. California residents have additional rights under the CCPA, including the right to know what data is shared, the right to opt out of data sale, and the right to deletion. GOVERNANCE EXPOSURE: Medium. The delegation of data sharing scope to a separate Privacy Policy creates a governance structure where users must review two documents to understand the full extent of data sharing authorized by account creation. Compliance teams should confirm that the Privacy Policy is incorporated by reference in a legally effective manner and that GLBA-required notices are current. JURISDICTION FLAGS: California residents have CCPA rights that may include the right to opt out of certain data sharing with third parties that constitutes a sale under the CCPA definition. Compliance with Virginia CDPA, Colorado Privacy Act, and other state privacy laws may create additional obligations depending on where users reside. CONTRACT AND VENDOR IMPLICATIONS: Merchant partners receiving consumer data through Affirm's sharing framework should ensure their own data handling practices comply with applicable privacy laws, as merchant receipt of Affirm user data may create independent GLBA or CCPA obligations for those merchants. COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the data sharing authorization in these terms is consistent with current GLBA and CCPA disclosure and opt-out requirements. An audit of the third-party recipients receiving consumer data under this authorization is recommended to ensure all downstream sharing is documented in the Privacy Policy.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces the Gramm-Leach-Bliley Act privacy requirements for non-bank financial institutions and has jurisdiction over deceptive data sharing practices
    File a complaint →
  • CFPB
    The CFPB has supervisory authority over data practices of consumer financial product providers and may examine GLBA compliance
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Affirm Terms of Service
Entity
Affirm
Document last updated
March 24, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-009586
Document ID
CA-D-00167
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a565ccb8559b7b4faae5dea17400c26c52091a269a6d5c0d2d79110102eac0c5
Analysis generated
May 8, 2026 09:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Affirm
Document: Affirm Terms of Service
Record ID: CA-P-009586
Captured: 2026-05-08 09:12:37 UTC
SHA-256: a565ccb8559b7b4f…
URL: https://conductatlas.com/platform/affirm/affirm-terms-of-service/data-sharing-with-third-parties/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Affirm's Data Sharing with Third Parties clause do?

Your transaction data and personal information may be shared with the merchants where you shop using Affirm and with other third parties, which affects your privacy beyond the Affirm platform itself.

How does this clause affect you?

This provision means that personal information, including your name, contact details, and purchase history, may be shared with merchants and third-party service providers, and the full scope of that sharing is governed by Affirm's separate Privacy Policy.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.

Is ConductAtlas affiliated with Affirm?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Affirm.