The policy authorizes PayPal to disclose Personal Information, including inferred product preferences, purchase history, sizes, and styles, to Partners and Merchants for personalized shopping experiences in the United States based on data collected after November 27, 2024, without requiring affirmative consent. Users may opt out through the Data and Privacy settings in their PayPal account.
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
This provision establishes an opt-out (rather than opt-in) framework for disclosure of behavioral and inferred data to third-party merchants and partners for personalized marketing purposes in the US, which may require evaluation under CCPA definitions of 'sharing' and GLBA nonaffiliate sharing provisions. The November 27, 2024 data cutoff creates a distinct operational boundary for existing customers versus new account holders.
⚠ Personal Information including inferred preferences, purchase history, and behavioral data will continue to be disclosed to Partners and Merchants for personalized shopping experiences as stated in the policy
Cross-platform context
See how other platforms handle Personalized Shopping Data Sharing with Partners and Merchants and similar clauses.
Compare across platforms →"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
(1) REGULATORY LANDSCAPE: This provision implicates the CCPA and CPRA, which regulate 'sharing' of personal information for cross-context behavioral advertising and require businesses to honor opt-out signals.
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This provision establishes an opt-out (rather than opt-in) framework for disclosure of behavioral and inferred data to third-party merchants and partners for personalized marketing purposes in the US, which may require evaluation under CCPA definitions of 'sharing' and GLBA nonaffiliate sharing provisions. The November 27, 2024 data cutoff creates a distinct operational boundary for existing customers versus new account holders.
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