“You agree that Apple has the right, without liability to you, to disclose any data and/or information to law enforcement authorities, government officials, and/or a third party, as Apple believes is reasonably necessary or appropriate to enforce and/or verify compliance...”
This analysis describes what Apple Pay'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 clause grants Apple Pay broad discretion to share any user data with a wide range of recipients, including private third parties, with no liability attaching to Apple for such disclosure.
Interpretive note: The scope of 'third party' is undefined, which means disclosures are not limited to government-adjacent actors. The standard 'as Apple believes is reasonably necessary or appropriate' is Apple's own assessment, not an objective standard. These are noted here and not softened in reader-facing prose.
The updated terms establish new restrictions on how users may employ Apple's services and content. Users are now explicitly prohibited from using Services, Content, or any outputs from them to train, fine-tune, or improve any artificial intelligence model or other software. For subscription commitments, refunds are limited to periods of access already paid for but not yet provided, with no refund due for future billing periods where payment has not yet been collected. Free trials or offers cannot be combined with any Apple Bundle (expanded from Apple One only), and trials will not be paused if you subscribe to an Apple Bundle, even if you have access to the same subscription through the bundle. You can cancel your subscription in your account settings at any time without additional charge if you do not wish to receive added services or features.
View change record →A reader's data may be disclosed to law enforcement, government officials, or third parties at Apple Pay's reasonable belief that such disclosure is necessary or appropriate, without any resulting legal claim against Apple.
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in the case of Cohere, to potential assignees, acquirers or successors of Cohere if and to the extent such persons need to know such Confidential Information in connection with a potential sale, merger, amalgamation or other corporate transaction...
Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.
"You agree that Apple has the right, without liability to you, to disclose any data and/or information to law enforcement authorities, government officials, and/or a third party, as Apple believes is reasonably necessary or appropriate to enforce and/or verify compliance...Excerpt from Apple Pay's Apple Media Services Terms
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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Companies change their terms without announcing it. We capture governance documents, compare each new version with the last, and publish what changed, with the source text behind it. One email a week on what we found and what we could not reach.
The clause grants Apple Pay broad discretion to share any user data with a wide range of recipients, including private third parties, with no liability attaching to Apple for such disclosure.
A reader's data may be disclosed to law enforcement, government officials, or third parties at Apple Pay's reasonable belief that such disclosure is necessary or appropriate, without any resulting legal claim against Apple.
ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Apple Pay.