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

EEA Quarterly Third-Party List Update with Deemed Consent

Unique · 0 of 343 platforms
Checked against the version captured Oct 8, 2026 (CA-V-007391); not re-checked against the current version.
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Document Record

What it is

Generated by a model from the captured document; not read by a person

PayPal reserves the right to update its list of third-party data recipients quarterly for EEA users; if users do not object within 30 days of each quarterly update, they are deemed to have consented to the updated disclosures. The only stated alternative to deemed acceptance is account closure.

ⓘ

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)

Generated by a model from the captured document; not read by a person

This provision establishes an inaction-based deemed-consent mechanism for updates to third-party data disclosure for EEA users, which may require evaluation under GDPR consent standards. GDPR generally requires that consent be freely given, specific, informed, and unambiguous; deemed consent derived from failure to object within a 30-day window may not satisfy these requirements, depending on regulatory interpretation.

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.
  • Close Your Account
    Within 30 days
    EEA users who object to quarterly updates to PayPal's third-party data recipient list should submit an objection via the PayPal Customer Service web portal or contact PayPal's DPO within 30 days of the quarterly update publication. The stated alternative for non-acceptance is to close your account and stop using PayPal services.

If You Do Nothing

⚠ Failure to object within 30 days of a quarterly third-party list update constitutes deemed acceptance of the new data disclosures and Privacy Statement changes, as stated in the terms

Cross-platform context

See how other platforms handle EEA Quarterly Third-Party List Update with Deemed Consent and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
PayPal may update the list of third parties referred to above on the first business day of every quarter (January, April, July and October). PayPal will only start transferring any Personal Information to any of the new entities or for the new purposes or Personal Information types indicated in each update after 30 days from the date when that list is made public through this Privacy Statement. You should review the list each quarter on the PayPal website on the dates stated above. If you do not object to the new Personal Information disclosure, within 30 days after the publication of the updated list of third parties, you are deemed to have accepted the changes to the list and to this Privacy Statement. If you do not agree with the changes, you may close your account and stop using our services.

Excerpt from PayPal's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: GDPR requires that consent be freely given, specific, informed, and indicated by a clear affirmative act.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • FTC
    While primary enforcement is with EEA supervisory authorities, FTC oversight of representations about consent mechanisms and cross-border data transfers may be relevant for US-connected operations
    File a complaint →

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Date stated by the document
Oct. 12, 2026
As printed in PayPal’s text (version CA-V-007492), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
March 6, 2026
Text quoted from version
CA-V-007492, captured Oct. 13, 2026
Document ID
CA-D-000045
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007492)
6b460d11eebe5f79304a0b57383ce00de3f3152405e9697466a0d956bde39e3c
Analysis generated
October 1, 2026 01:58 UTC
Methodology
Evidence
Excerpt not yet checked against a stored version
Citation Record
Entity: PayPal
Document: PayPal Privacy Statement
Version: CA-V-007492
Captured: 2026-10-13 00:10:18 UTC
SHA-256: 6b460d11eebe5f79…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/eea-quarterly-third-party-list-update-with-deemed-consent/
Accessed: Oct. 22, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

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Frequently Asked Questions

What does PayPal's EEA Quarterly Third-Party List Update with Deemed Consent clause do?

This provision establishes an inaction-based deemed-consent mechanism for updates to third-party data disclosure for EEA users, which may require evaluation under GDPR consent standards. GDPR generally requires that consent be freely given, specific, informed, and unambiguous; deemed consent derived from failure to object within a 30-day window may not satisfy these requirements, depending on regulatory interpretation.

Is ConductAtlas affiliated with PayPal?

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