Cash App states it uses data collected about you to develop a credit risk profile assessing your creditworthiness and to draw inferences about your preferences, characteristics, 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 policy states that credit risk profiles are developed from collected data; if these profiles are used in credit eligibility determinations, they may interact with Fair Credit Reporting Act (FCRA) obligations regarding adverse action notices and consumer dispute rights.
Interpretive note: Whether the credit risk profiles described constitute consumer reports under FCRA depends on how they are used in eligibility determinations, which is not fully specified in the notice.
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 creates credit risk profiles and behavioral inferences about users to assess creditworthiness and maintain profiles of personal characteristics.
View full change record →The policy states that Cash App develops credit risk profiles and draws behavioral inferences from collected data; users who are denied or restricted from certain financial products or services based on these profiles may have rights under the FCRA to receive adverse action notices and dispute inaccurate information depending on how these profiles are used.
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"Developing a credit risk profile about you to assess your creditworthiness; 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 development of credit risk profiles from collected data engages the Fair Credit Reporting Act (FCRA) if such profiles constitute consumer reports used in credit eligibility determinations, enforced by the CFPB and …
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The policy states that credit risk profiles are developed from collected data; if these profiles are used in credit eligibility determinations, they may interact with Fair Credit Reporting Act (FCRA) obligations regarding adverse action notices and consumer dispute rights.
The policy states that Cash App develops credit risk profiles and draws behavioral inferences from collected data; users who are denied or restricted from certain financial products or services based on these profiles may have rights under the FCRA to receive adverse action notices and dispute inaccurate information depending on how these profiles are used.
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