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The policy states that PayPal does not respond to browser Do Not Track signals because many of its services require tracking data to function. Users seeking to limit tracking are directed to the About Ads resource.
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
Several US state privacy laws, including those in Colorado, Connecticut, and other states, address universal opt-out signals for targeted advertising, and compliance teams should evaluate whether PayPal's DNT non-response posture satisfies the opt-out signal honoring requirements of applicable state laws.
Interpretive note: Whether PayPal's DNT non-response posture satisfies state universal opt-out signal requirements depends on the technical implementation of its alternative opt-out mechanisms and the specific requirements of each applicable state law.
Under this clause, PayPal does not alter its data collection or tracking practices in response to browser Do Not Track signals. Users seeking to limit interest-based advertising tracking must use alternative mechanisms such as account privacy settings or industry opt-out tools referenced in the policy.
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"Some web browsers have an optional setting called "Do Not Track" ("DNT") that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won't function without tracking data, we do not respond to DNT settings.Excerpt from PayPal's Privacy Statement
(1) REGULATORY LANDSCAPE: The Do Not Track standard is not mandated by federal law, and the FTC has not issued a final rule requiring commercial website compliance with DNT signals. California law (California Online Privacy Protection Act) previously required disclosure of DNT response practices, which this policy satisfies by explicitly stating non-compliance. The CCPA/CPRA does not require DNT signal compliance but does require opt-out of sale or sharing for cross-context behavioral advertising, which the policy addresses separately. (2) GOVERNANCE EXPOSURE: Low. Non-response to DNT signals is a common disclosed practice and is not independently prohibited by current U.S. federal or California law. The disclosure is transparent and complies with applicable notice requirements. (3) JURISDICTION FLAGS: California's Online Privacy Protection Act requires disclosure of DNT response practices, which this policy satisfies. EU/EEA users are covered by separate cookie consent mechanisms under ePrivacy Directive requirements, which are addressed elsewhere in the policy. (4) CONTRACT AND VENDOR IMPLICATIONS: No material vendor or contract implications arise from this provision standing alone; the tracking practices enabled by non-DNT-response are governed by the broader cookies and tracking technologies section of the policy. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should ensure that account-level opt-out mechanisms for interest-based advertising are functional and that the About Ads reference in the policy directs users to a current and operative opt-out resource.
Several US state privacy laws, including those in Colorado, Connecticut, and other states, address universal opt-out signals for targeted advertising, and compliance teams should evaluate whether PayPal's DNT non-response posture satisfies the opt-out signal honoring requirements of applicable state laws.
Under this clause, PayPal does not alter its data collection or tracking practices in response to browser Do Not Track signals. Users seeking to limit interest-based advertising tracking must use alternative mechanisms such as account privacy settings or industry opt-out tools referenced in the policy.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by PayPal.