PayPal · PayPal Privacy Statement

Contact Information Sharing Certification

Medium severity
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What it is

If you import your phone or email contacts into PayPal, you are certifying that those contacts have given you permission to share their data with PayPal — even though most contacts likely do not know this is happening.

Consumer impact (what this means for users)

If you sync your contacts with PayPal, the policy places legal responsibility on you for obtaining those contacts' consent — but your contacts likely have no idea their name, phone number, and email are now in PayPal's systems.

How other platforms handle this

Microsoft Medium

Personal data collected by Microsoft may be stored and processed in the United States or any other country where Microsoft or its affiliates, subsidiaries, or service providers maintain facilities. Microsoft complies with applicable legal frameworks relating to the transfer of data across borders, i...

Google Medium

We will share personal information outside of Google if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process, or enforceable governmental request.

Bank of America Medium

For joint marketing with other financial companies. Yes. No.

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Why it matters (compliance & risk perspective)

This clause shifts legal responsibility for third-party contact data to the PayPal user, while PayPal collects data on people who never agreed to or knew about PayPal's privacy practices.

View original clause language
Process information about your contacts. We may use Personal Information in order to make it easy for you to find and connect your contacts, improve payment accuracy and suggest connections with people you may know. By providing us with information about your contacts you certify that you have permission to provide that information to PayPal for the purposes described in this Privacy Statement.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: CCPA/CPRA §1798.100 applies to personal information collected about third parties; collecting contact data about non-users without their knowledge may trigger notice-at-collection obligations for those individuals. GDPR Arts. 13–14 require notice to individuals whose data is collected, including from third-party sources; contact import without notice to the data subject raises compliance concerns. COPPA 16 C.F.R. Part 312 applies if contact lists include children's data. FTC Act Section 5 applies to practices that shift responsibility for third-party data collection to consumers without meaningful disclosure.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over third-party contact data collection practices and the sufficiency of disclosure and consent mechanisms under FTC Act Section 5.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
CAN-SPAM
United States Federal
DMA
European Union
FCRA
United States Federal
GDPR
European Union
GLBA
United States Federal
HIPAA
United States Federal
UK GDPR
United Kingdom

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
April 29, 2026
Tracking information
First tracked
March 6, 2026
Last verified
April 10, 2026
Record ID
CA-P-002676
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
SHA-256
a5efa287f0b43a6a87f7dfc939ccb3c8edfb0ea67f476b2afeddf66fffa27690
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: PayPal | Document: PayPal Privacy Statement | Record: CA-P-002676
Captured: 2026-03-06 20:34:43 UTC | SHA-256: a5efa287f0b43a6a…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/contact-information-sharing-certification/
Accessed: April 29, 2026
Classification
Severity
Medium
Categories

Other provisions in this document

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