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The document authorizes Klarna to share personal data with cloud computing platforms, payment service providers, advertising and marketing partners, and regulatory authorities, for purposes including fraud prevention, credit risk assessment, and marketing and advertising.
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
This provision authorizes sharing of personal data, which may include financial and behavioral data, with advertising and marketing partners, a category that engages GLBA NPI sharing opt-out requirements and CCPA sale or sharing disclosure obligations given the nature of the data Klarna processes.
Under this provision, personal data including purchase history, interaction data, and financial details may be shared with advertising and marketing partners depending on the services used. The agreement provides a GLBA-based opt-out mechanism for limiting sharing of non-public personal information with unaffiliated third parties, accessible through the Klarna app or web app settings.
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"Depending on the service you wish to use, we may need to share some of your data with a select number of third parties, for example partners (cloud computing platforms, payment service providers or advertising or marketing partners) or authorities. To give you some examples, the reason for this may be so we can store your data safely, administer your purchases with stores, abide by regulatory requirements, prevent fraud, carry out credit risk assessments, or conduct marketing or advertising.Excerpt from Klarna's Privacy Policy
1) REGULATORY LANDSCAPE: GLBA requires financial institutions to provide notice and opt-out rights before sharing NPI with unaffiliated third parties, and this provision directly implicates that requirement given Klarna's bank status. CCPA requires disclosure of whether personal information is sold or shared with third parties for cross-context behavioral advertising and provides consumers a right to opt out. GDPR requires a lawful basis and, in many cases, consent for sharing personal data with advertising partners. The CFPB and FTC hold enforcement authority in the US context. 2) GOVERNANCE EXPOSURE: High. The authorization to share financial and behavioral data with advertising and marketing partners, combined with Klarna's bank status, creates heightened GLBA compliance obligations. The document does not specify which data categories are shared with advertising partners or the contractual constraints on those partners' use of the data, which may create disclosure gaps. 3) JURISDICTION FLAGS: California residents have CCPA rights to opt out of sale or sharing of personal information and to receive a list of third parties with whom information is shared. EU users have GDPR rights requiring consent or legitimate interest assessments for advertising data sharing. UK users are subject to UK GDPR. GLBA applies to all US users given Klarna's financial institution status. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams assessing Klarna as a vendor should review whether data processing agreements with Klarna specify which advertising and marketing partners receive data and what contractual restrictions govern those partners' use. The provision does not assert audit rights over advertising partners. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the full Privacy Policy identifies all advertising and marketing partners receiving personal data, specifies the categories of data shared, and provides CCPA-compliant opt-out mechanisms. GLBA annual privacy notice obligations should be reviewed to confirm that advertising partner sharing is disclosed and that opt-out procedures are adequate.
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This provision authorizes sharing of personal data, which may include financial and behavioral data, with advertising and marketing partners, a category that engages GLBA NPI sharing opt-out requirements and CCPA sale or sharing disclosure obligations given the nature of the data Klarna processes.
Under this provision, personal data including purchase history, interaction data, and financial details may be shared with advertising and marketing partners depending on the services used. The agreement provides a GLBA-based opt-out mechanism for limiting sharing of non-public personal information with unaffiliated third parties, accessible through the Klarna app or web app settings.
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