PayPal · PayPal Privacy Statement

AI Model Training Using Personal Information

High severity
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What it is

PayPal uses your personal data — including your transaction history and account information — to train its AI systems, and also uses automated systems to make decisions about fraud risk and product eligibility.

Consumer impact (what this means for users)

PayPal uses your transaction history, browsing behavior, and other personal data to train AI models, and automated decision-making tools may affect whether you are flagged for fraud or approved for financial products without a human reviewing your case.

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.
  • Export Your Data
    Log in to your PayPal account, go to Settings > Privacy, and submit a data access or portability request to understand what personal data PayPal holds and uses for AI training.

Cross-platform context

See how other platforms handle AI Model Training Using Personal Information and similar clauses.

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Why it matters (compliance & risk perspective)

Your financial and behavioral data is being used to train AI models, and automated systems are making consequential decisions about you without human review, which can affect your access to services and your financial standing.

View original clause language
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.

Institutional analysis (Compliance & legal intelligence)

1. REGULATORY FRAMEWORK: This provision implicates GDPR Art. 22 (automated decision-making including profiling), which grants individuals the right not to be subject to solely automated decisions with significant effects, and requires disclosure of meaningful information about the logic involved. The EU AI Act (Regulation 2024/1689) classifies credit scoring and fraud detection AI as high-risk AI systems under Annex III, requiring conformity assessments and transparency obligations. CCPA/CPRA does not provide an explicit automated decision-making opt-out right but the CPPA has proposed regulations. FTC Act Section 5 applies to deceptive or unfair AI practices. 2.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over unfair or deceptive AI data practices and has taken action against companies that misuse consumer data for AI training without adequate disclosure.
    File a complaint →
  • CFPB
    The CFPB has authority over automated decision-making in consumer financial services, including credit and fraud determinations that affect consumers' financial access.
    File a complaint →

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
April 29, 2026
Tracking information
First tracked
April 18, 2026
Last verified
April 28, 2026
Record ID
CA-P-003928
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
SHA-256
88e15ed1ee29a80c15e1f44d4a7a869e4f68a15049f8669d6949ec87c64d86cb
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: PayPal | Document: PayPal Privacy Statement | Record: CA-P-003928
Captured: 2026-04-18 08:48:00 UTC | SHA-256: 88e15ed1ee29a80c…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/ai-model-training-using-personal-information/
Accessed: May 2, 2026
Classification
Severity
High
Categories

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