The policy states that PayPal transfers Personal Information internationally and that by using the services, users in jurisdictions where such consent is permitted agree to cross-border data transfers including to countries with different data protection standards. For EU users, intra-company Binding Corporate Rules and Standard Contractual Clauses are cited as transfer mechanisms.
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
The policy's use of 'by using our Sites and Services, where permitted under applicable privacy laws, you agree to your Personal Information being transferred' as a transfer consent mechanism may require evaluation under GDPR, which does not recognize general terms-of-service consent as a valid transfer mechanism for Article 46 purposes; instead, specific transfer mechanisms such as adequacy decisions, SCCs, or BCRs are required.
⚠ Personal Information will be transferred to other countries, including those with different data protection standards, as stated in the policy, with protection mechanisms applied as described
Cross-platform context
See how other platforms handle International Data Transfers and Consent by Use and similar clauses.
Compare across platforms →"We operate in many countries, and we (or our service providers) may transfer your Personal Information and process it outside the country where you live. For example, we use third-party service providers to process and store your Personal Information in the United States and other countries. These countries do not always afford a level of privacy protection that is equivalent to the protection offered to Personal Information in your country. We have taken and will continue to take specific steps, in accordance with the applicable data protection and privacy laws, to protect your Personal Information (e.g., intra-company agreements, model contractual clauses, and/or derogations). By using our Sites and Services, where permitted under applicable privacy laws, you agree to your Personal Information being transferred to other countries, including countries that have different data protection rules than your country.Excerpt from PayPal's Privacy Statement
(1) REGULATORY LANDSCAPE: GDPR Chapter V governs international data transfers from the EEA and requires either an adequacy decision, appropriate safeguards (SCCs, BCRs), or a derogation under Article 49.
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The policy's use of 'by using our Sites and Services, where permitted under applicable privacy laws, you agree to your Personal Information being transferred' as a transfer consent mechanism may require evaluation under GDPR, which does not recognize general terms-of-service consent as a valid transfer mechanism for Article 46 purposes; instead, specific transfer mechanisms such as adequacy decisions, SCCs, or …
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