PayPal · PayPal Privacy Statement

Non-Account Holder Data Collection

High severity
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What it is

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.

Why it matters

Consumers who believe they are transacting without a PayPal account and without PayPal's data practices applying to them are mistaken — their data is collected and may be retrospectively linked to a later-created account.

Consumer impact

PayPal collects an exceptionally broad range of personal data — including biometrics, precise geolocation, inferred creditworthiness, and full financial histories — and shares it with partners, merchants, credit reporting agencies, data brokers, and members of the PayPal corporate group. Automated decision-making, including AI-driven risk and fraud assessments, can directly affect your account status, credit access, and transaction approvals without transparent human review. You can review and limit certain data uses by visiting your PayPal account privacy settings at paypal.com/us/myaccount/privacy.

Applicable agencies

  • FTC
    The FTC has enforcement authority over deceptive data collection practices from non-account holders under FTC Act Section 5.
    File a complaint →
  • State AG
    California AG and CPPA enforce CCPA/CPRA notice at collection requirements for non-account holder data, and other state AGs enforce analogous state privacy statutes.
    File a complaint →

Provision details

Document information
Document
PayPal Privacy Statement
Entity
PayPal
Document last updated
March 24, 2026
Tracking information
First tracked
March 6, 2026
Last verified
April 10, 2026
Record ID
CA-P-002672
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-002672
Captured: 2026-03-06 20:34:43 UTC | SHA-256: a5efa287f0b43a6a…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/non-account-holder-data-collection/
Accessed: April 17, 2026
Classification
Severity
High
Categories

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