Klarna · Klarna Privacy Policy · View original document ↗

Legitimate Interest as Legal Basis for Profiling and Marketing

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

Klarna uses a legal justification called 'legitimate interest' to analyze your data and send you personalized marketing without asking for your explicit consent each time, though you can object to this processing.

This analysis describes what Klarna'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)

Using legitimate interest rather than consent as a legal basis means Klarna does not need to ask your permission for certain profiling and marketing activities, though you retain the right to object, which may not be prominently communicated in the user experience.

Interpretive note: Whether Klarna's legitimate interest assessments for specific profiling activities have been documented and would withstand regulatory scrutiny cannot be assessed from the policy text alone; the adequacy of the balancing test is not disclosed.

Change history

modified Jun 2, 2026

Previous generic provision renamed and expanded to explicitly mention profiling and marketing with added emphasis on user right to object.

View full change record →

Consumer impact (what this means for users)

Klarna may profile your shopping and payment behavior and use that data for targeted marketing based on its own assessment that this is in its legitimate interest; you have the right to object to this processing, and doing so should cause Klarna to stop using your data for those purposes unless it can demonstrate compelling grounds to override your objection.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Navigate to privacy settings in the Klarna app or visit klarna.com, find the option to object to or restrict data processing for marketing and profiling purposes, and submit your objection through the privacy request portal.

How other platforms handle this

Medium Medium

If you are in the European Economic Area (EEA), we only process your personal data when we have a valid legal basis to do so, including when: (a) you have consented to the processing; (b) the processing is necessary to perform a contract with you; (c) we have a legitimate interest in processing your...

Tinder Medium

We may disclose your information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose your information if we believe it...

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
We process your personal data based on our legitimate interests, for example to send you marketing communications, to personalize your experience, to carry out analytics and research, and to improve our products and services. You have the right to object to this processing at any time.

— Excerpt from Klarna's Klarna Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Reliance on legitimate interest as a legal basis for profiling and marketing engages GDPR Article 6(1)(f) and requires a three-part test: the legitimate interest must be identified, the processing must be necessary for that interest, and the interest must not be overridden by the data subject's rights and interests. The European Data Protection Board has issued guidance indicating that marketing profiling on legitimate interest grounds is subject to heightened scrutiny. Relevant enforcement authorities include national DPAs and the Irish DPC as Klarna's likely EU lead supervisory authority. GOVERNANCE EXPOSURE: Medium. The use of legitimate interest for behavioral profiling and marketing analytics is not inherently impermissible under GDPR but has attracted significant regulatory attention. The adequacy of the balancing test documentation and the prominence of the right-to-object disclosure in the user interface are key compliance variables. JURISDICTION FLAGS: EU and UK users have a statutory right to object to processing based on legitimate interest under GDPR Article 21, and upon valid objection the controller must cease processing unless compelling legitimate grounds are demonstrated. In California, certain profiling activities may qualify as the sale or sharing of personal information under the CPRA, triggering opt-out rights regardless of the legal basis asserted. CONTRACT AND VENDOR IMPLICATIONS: Marketing technology vendors and analytics partners receiving data under Klarna's legitimate interest processing should be assessed for whether their own processing activities are compatible with the original legitimate interest basis. Data processing agreements should clearly delineate the permissible purposes for which shared data may be used. COMPLIANCE CONSIDERATIONS: Compliance teams should ensure that documented legitimate interest assessments are maintained and up to date for each identified processing purpose. The right to object must be communicated clearly and at the first communication with the user, per GDPR Article 21(4). User interface audits should confirm that the objection mechanism is as easy to exercise as the opt-in.

Full compliance analysis

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices related to consumer data profiling and behavioral advertising, including whether opt-out mechanisms are genuinely accessible
    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
TCPA
United States Federal
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Klarna Privacy Policy
Entity
Klarna
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
May 10, 2026
Record ID
CA-P-009283
Document ID
CA-D-00166
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
bfbac757c06748a3aa551a759cd3abf415605416813542dd2a529a21bc5bd714
Analysis generated
April 27, 2026 13:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Klarna
Document: Klarna Privacy Policy
Record ID: CA-P-009283
Captured: 2026-04-27 13:38:29 UTC
SHA-256: bfbac757c06748a3…
URL: https://conductatlas.com/platform/klarna/klarna-privacy-policy/legitimate-interest-as-legal-basis-for-profiling-and-marketing/
Accessed: June 9, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Klarna's Legitimate Interest as Legal Basis for Profiling and Marketing clause do?

Using legitimate interest rather than consent as a legal basis means Klarna does not need to ask your permission for certain profiling and marketing activities, though you retain the right to object, which may not be prominently communicated in the user experience.

How does this clause affect you?

Klarna may profile your shopping and payment behavior and use that data for targeted marketing based on its own assessment that this is in its legitimate interest; you have the right to object to this processing, and doing so should cause Klarna to stop using your data for those purposes unless it can demonstrate compelling grounds to override your objection.

Is ConductAtlas affiliated with Klarna?

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