Provision record
PayPal · PayPal Privacy Statement · View original document ↗

AI Model Training on Personal Data

High severity Common · 284 of 352 platforms
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Document Record

What it is

PayPal uses your personal data — including your transactions, behavior, and financial history — to train its AI systems, and also uses AI to automatically make decisions about fraud risk and service access.

This analysis describes what PayPal'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)

The clause establishes PayPal's operational authority to incorporate user data into AI model development and to apply automated decision systems for security and fraud mitigation functions. This defines the scope of permissible data uses beyond transaction processing and direct service provision.

Clause Stability Stable

0
Changes
4
Months Monitored
Apr 5, 2026
First Seen
Apr 10, 2026
Last Seen
This clause type exists across 3394 other provisions on other platforms.

Consumer impact (what this means for users)

Your transaction history, browsing behavior, and inferred financial data may be used to train PayPal's AI models, and AI-driven automated decisions can affect your account access, fraud flags, and credit assessments without a clearly described opt-out.

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
    Log in to PayPal, go to Settings > Privacy, and submit a request to opt out of personal data use for AI training or profiling purposes. EU/UK users may exercise Art. 21 GDPR objection rights via the same portal.

How other platforms handle this

ZipRecruiter Medium

We will only use your Personal Data to provide services directly to you...and/or to provide services to you on behalf of our clients...except as otherwise described in this Privacy Policy or with your consent.

Glassdoor Medium

We may use your personal data to conduct research...we conduct and publish research about the labor market, the economy, job opportunities, jobseeker and employee behaviors...

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

See all platforms with this clause type →

Monitoring

PayPal has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
AI and Automated Decision Making. We may use Personal Information to train our artificial intelligence (AI) models that power our Services and help us deliver more secure, efficient, and personalized services. PayPal also uses Automated Decision Making to provide our products and Services, conduct risk analysis, fraud prevention and risk management to protect our customers and business, including to prevent fraud against our Partners and Merchants and strategic ventures.

Excerpt from PayPal's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY FRAMEWORK: GDPR Art. 22 grants data subjects the right not to be subject to solely automated decisions producing legal or similarly significant effects, with exceptions requiring explicit consent, contractual necessity, or legal authorization; Art. 21 right to object to processing based on legitimate interests applies to AI training. CPRA §1798.185(a)(16) requires CPPA regulations on automated decision-making opt-outs. EU AI Act (Regulation 2024/1689) classifies credit scoring and fraud detection AI as high-risk systems (Annex III) subject to conformity assessments, transparency requirements, and human oversight obligations. FTC Act Section 5 applies to deceptive AI disclosures.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has enforcement authority over deceptive AI data practices under Section 5 and has prioritized commercial surveillance and AI training data issues.
    File a complaint →
  • CFPB
    The CFPB has authority over automated decision-making in credit and financial services contexts under ECOA and FCRA where AI-driven decisions affect credit access.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
TCPA
United States Federal
UK GDPR
United Kingdom

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
May 5, 2026
Tracking information
First tracked
March 6, 2026
Last verified
April 10, 2026
Record ID
CA-P-002262
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a5efa287f0b43a6a87f7dfc939ccb3c8edfb0ea67f476b2afeddf66fffa27690
Analysis generated
March 6, 2026 20:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: PayPal
Document: PayPal Privacy Statement
Record ID: CA-P-002262
Captured: 2026-03-06 20:34:43 UTC
SHA-256: a5efa287f0b43a6a…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/provision/CA-P-002262/ai-model-training-on-personal-data/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does PayPal's AI Model Training on Personal Data clause do?

The clause establishes PayPal's operational authority to incorporate user data into AI model development and to apply automated decision systems for security and fraud mitigation functions. This defines the scope of permissible data uses beyond transaction processing and direct service provision.

How does this clause affect you?

Your transaction history, browsing behavior, and inferred financial data may be used to train PayPal's AI models, and AI-driven automated decisions can affect your account access, fraud flags, and credit assessments without a clearly described opt-out.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 284 platforms. See the full comparison.

Is ConductAtlas affiliated with PayPal?

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