This analysis describes what Cash App'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 establishes a broad operational authorization for AI/ML model training using customer data across multiple institutional functions—service improvement, fraud detection, and security protection—creating a systematic data use pathway distinct from other stated purposes.
The updated policy establishes that children under 13 may use Cash App services if a parent or guardian signs up for or authorizes the account on their behalf. Previously, the policy explicitly prohibited any use by children under 13. The revised language clarifies that data deletion obligations apply when Cash App learns an account belongs to an unauthorized child under 13, but does not specify what happens to data from authorized child accounts or how parental oversight operates. A separate Privacy Notice for Children is referenced but not included in the change summary.
View change record →The revised policy shifts from prohibiting all children under 13 from using Cash App to permitting use when a parent or guardian explicitly authorizes or signs up for the service on the child's behalf. This creates a new lawful use path for families, but also establishes a distinction between authorized and unauthorized child accounts. The policy states that if a child under 13 operates an unauthorized account, Cash App will delete collected data upon discovery. Parents or guardians who authorize services should review the new Privacy Notice for Children for details on how child data is processed.
View change record →The updated terms state that children under 13 can no longer use Cash App, eliminating a path that previously existed for parents to authorize accounts on behalf of younger children. The revised language no longer references a separate Privacy Notice for Children, consolidating all child data handling disclosures into the main policy. If Cash App collects data and later learns it came from a child under 13, the policy requires deletion of that data, though the updated language broadens this obligation by removing the phrase 'for an unauthorized account', potentially extending deletion requirements beyond accounts that were never authorized.
View change record →Users' transactional and account data may be incorporated into Cash App's AI and machine learning systems to enhance service personalization, fraud prevention, and security operations. This data use occurs automatically as part of service operations rather than requiring separate user authorization.
How other platforms handle this
We may use aggregated, de-identified data derived from your use of our services, including document metadata and usage patterns, to develop, train, and improve our artificial intelligence and machine learning models and product features.
engage in any of the foregoing in connection with any use, creation, development, modification, prompting, fine-tuning, training, testing, benchmarking or validation of any artificial intelligence or machine learning tool, model, system, algorithm, product or other technology ("AI Tool").
Data publicly available on the Internet. Our artificial intelligence models are trained on data that is publicly available on the Internet by third parties, which may contain personal data, even if we use good practices to filter out such personal data. [...] Training Datasets. In some cases, we acc...
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"Improving, personalizing and facilitating your use of our Services, content and applications, including by training artificial intelligence (AI) and other machine learning models; ... Making sure you follow our Terms of Service or other applicable agreements or policies; Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf; Protecting your, our, or our other customers' rights or property, or the security or integrity of our Services, including by using and training AI and other machine learning models to protect— Excerpt from Cash App's Cash App Privacy Policy
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The clause establishes a broad operational authorization for AI/ML model training using customer data across multiple institutional functions—service improvement, fraud detection, and security protection—creating a systematic data use pathway distinct from other stated purposes.
Users' transactional and account data may be incorporated into Cash App's AI and machine learning systems to enhance service personalization, fraud prevention, and security operations. This data use occurs automatically as part of service operations rather than requiring separate user authorization.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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