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

Non-Account Holder Data Collection

Medium severity High confidence Explicitdocumentlanguage Common · 295 of 352 platforms
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Recent governance activity PayPal recorded 4 documented changes in the last 30 days.
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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 establishes that PayPal's data collection applies to individuals who have not affirmatively created a PayPal account, including recipients of payments via Visa+ and users of merchant-embedded Braintree payment flows. The retroactive linking of non-account transaction data to a subsequently created account is a distinct data association practice.

Clause Stability Stable

0
Changes
4
Months Monitored
Apr 10, 2026
First Seen
Jul 9, 2026
Last Seen
This clause type exists across 5261 other provisions on other platforms.

Change history

modified Jul 14, 2026

Provision name updated from "Non-Account Holder Data Collection" to "Non-Account Holder Data Collection and Transaction Linking" to reflect expanded scope.

View full change record →

How other platforms handle this

Baseten Medium

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

Skillshare Medium

In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format

Discord Medium

If you want to see what information we have collected about you, you can request a copy of your data in the Data & Privacy section of your User Settings. You should receive your data packet within 30 days.

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Monitoring

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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 Privacy Statement

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
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
July 9, 2026
Last verified
July 25, 2026
Record ID
CA-P-002672
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-002672
Captured: 2026-07-09 04:08:48 UTC
SHA-256: 323a171a636780ae…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/provision/CA-P-002672/non-account-holder-data-collection/
Accessed: July 25, 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 clause do?

This provision establishes that PayPal's data collection applies to individuals who have not affirmatively created a PayPal account, including recipients of payments via Visa+ and users of merchant-embedded Braintree payment flows. The retroactive linking of non-account transaction data to a subsequently created account is a distinct data association practice.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.

Is ConductAtlas affiliated with PayPal?

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