Cash App states it may use your personal data including transaction history, behavioral data, and profile information to train AI and machine learning models and to draw inferences that build a profile about your credit risk, preferences, and shopping habits.
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 authorization to use personal data for AI training is explicit and broad, and the notice does not describe limits on which data categories may be used for this purpose or how long AI-trained models derived from user data are retained.
Interpretive note: The notice does not specify which data categories are included in or excluded from AI training, and the scope of profiling opt-out rights available to non-California users depends on the applicable state law framework.
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 →New explicit disclosure that Cash App trains AI and machine learning models on user data and creates behavioral profiles for service enhancement.
View full change record →The policy states that data including transaction history, behavioral data, and inferred characteristics may be used to train AI models and build profiles reflecting credit risk, preferences, and shopping habits; California residents have a right to opt out of profiling under the CPRA, and users in other states with profiling opt-out rights under applicable state laws may also be entitled to limit this use.
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to request that your data be transferred to a third party (data portability)
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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; Drawing inferences from any of the information we collect to create a profile about you that may reflect, for example, your credit risk profile, your preferences, characteristics, shopping habits, and other behavior, to enhance our Services to you and maintain a trusted environment;Excerpt from Cash App's Privacy Policy
1) REGULATORY LANDSCAPE: The CCPA/CPRA grants California residents the right to opt out of automated decision-making and profiling, enforced by the California Privacy Protection Agency.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The authorization to use personal data for AI training is explicit and broad, and the notice does not describe limits on which data categories may be used for this purpose or how long AI-trained models derived from user data are retained.
The policy states that data including transaction history, behavioral data, and inferred characteristics may be used to train AI models and build profiles reflecting credit risk, preferences, and shopping habits; California residents have a right to opt out of profiling under the CPRA, and users in other states with profiling opt-out rights under applicable state laws may also be entitled …
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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