PayPal · PayPal Privacy Statement · View original document ↗

Non-Account Holder Data Collection and Linking

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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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)

This provision means that people who have never agreed to PayPal's terms of service may still have their personal and transaction data collected, and that data may be retroactively linked to a formal account, expanding PayPal's data profile of that individual.

Consumer impact (what this means for users)

The statement authorizes PayPal to collect biometric data including face scans and voice identification, infer sensitive attributes such as income and creditworthiness from transaction behavior, and share personal information with data brokers, credit reporting agencies, fraud prevention agencies, and financial institutions. PayPal also discloses that it uses personal information to train AI models and applies automated decision-making to risk analysis, fraud prevention, and product delivery, with limited mechanisms for users outside the EU and UK to object to these uses. You can review and adjust your privacy settings, including opting out of targeted advertising and managing data sharing preferences, by visiting https://www.paypal.com/us/myaccount/privacy/profiles/search.

How other platforms handle this

PlanetScale Medium

When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...

American Airlines Medium

American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...

GOAT Medium

We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.

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▸ View Original Clause Language DOCUMENT RECORD
"
Our Services may be accessed by individuals without a PayPal account or profile. We will collect Personal Information from you even if you are a non-account holder when you use our Services, such as when you use our Pay without a PayPal Account, use Unbranded Payment Services (e.g., Braintree), use a Fastlane profile, or when you receive a payment through the Visa+ service from a PayPal account holder or a payment from a payor using the Hyperwallet services. If you Pay without a PayPal account, we may link your transaction information with your PayPal account if you create a PayPal account later.

— Excerpt from PayPal's PayPal Privacy Statement

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
TCPA
United States Federal
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-007900
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3472030bc5dcca97c07809d8a57c82459fa06f7e44c6e287a15f7ba1c512805e
Analysis generated
May 10, 2026 00:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: PayPal
Document: PayPal Privacy Statement
Record ID: CA-P-007900
Captured: 2026-05-10 00:17:27 UTC
SHA-256: 3472030bc5dcca97…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/non-account-holder-data-collection-and-linking/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does PayPal's Non-Account Holder Data Collection and Linking clause do?

This provision means that people who have never agreed to PayPal's terms of service may still have their personal and transaction data collected, and that data may be retroactively linked to a formal account, expanding PayPal's data profile of that individual.

Is ConductAtlas affiliated with PayPal?

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