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

Partner and Merchant Personalized Shopping Data Disclosure

High severity Unique · 0 of 352 platforms
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Document Record

What it is

The policy states that for US users, PayPal discloses Personal Information collected after November 27, 2024, to Partners and Merchants for personalized shopping experiences without requiring affirmative consent, relying instead on an opt-out mechanism in account Data and Privacy settings. Disclosed data includes inferred product preferences, sizes, and styles.

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 establishes an opt-out rather than opt-in framework for disclosing inferred behavioral profiles and product preference data to Partners and Merchants. Once disclosed, the handling of that data is governed by Partners' and Merchants' own privacy policies, not PayPal's.

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.
  • Opt Out of Arbitration
    Log into your PayPal account, navigate to the Data and Privacy section in your account settings, and edit your preferences to opt out of Personal Information sharing with Partners and Merchants for personalized shopping experiences.

If You Do Nothing

Personal Information including inferred product preferences and behavioral profiles will continue to be disclosed to Partners and Merchants for personalized shopping experiences as described in the policy

Cross-platform context

See how other platforms handle Partner and Merchant Personalized Shopping Data Disclosure and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Unless we are required by law to obtain your consent, we disclose Personal Information collected from you after November 27, 2024 (or from earlier if you consent) for personalized shopping experiences in the United States. To opt-out of disclosures of Personal Information to Partners and Merchants for personalized shopping experiences, log into your PayPal account and edit your preferences in the Data and Privacy setting. If you opt-out, we will continue to disclose your Personal Information as necessary to complete transactions you initiate but will not disclose Personal Information to Partners and Merchant for personalized shopping experiences.

Excerpt from PayPal's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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

Applicable agencies

  • FTC
    The FTC has jurisdiction over data sharing practices that may constitute unfair or deceptive acts, including disclosure of behavioral profiles to third parties in ways that may not align with consumer expectations
    File a complaint →
  • State AG
    California, Vermont, and North Dakota state attorneys general have jurisdiction over compliance with state financial privacy laws and CCPA opt-out requirements applicable to this disclosure practice
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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
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
July 9, 2026
Last verified
Aug. 3, 2026
Record ID
CA-P-00045002
Document ID
CA-D-00045
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
323a171a636780ae11796995ce3314342502ac7d4a05f085477133259b344eb1
Analysis generated
July 9, 2026 04:08 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: PayPal
Document: PayPal Privacy Statement
Record ID: CA-P-00045002
Captured: 2026-07-09 04:08:48 UTC
SHA-256: 323a171a636780ae…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/partner-and-merchant-personalized-shopping-data-disclosure/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does PayPal's Partner and Merchant Personalized Shopping Data Disclosure clause do?

This provision establishes an opt-out rather than opt-in framework for disclosing inferred behavioral profiles and product preference data to Partners and Merchants. Once disclosed, the handling of that data is governed by Partners' and Merchants' own privacy policies, not PayPal's.

Is ConductAtlas affiliated with PayPal?

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