What is the severity of this clause?

ConductAtlas classifies this Collection of Personal Information From Non-Account Holders clause as medium severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Do other platforms have similar clauses?

Yes. ConductAtlas has identified similar Collection of Personal Information From Non-Account Holders clauses across approximately 300 other tracked platforms. You can compare how platforms differ on this clause type in the cross-platform comparison view.

Collection of Personal Information From Non-Account Holders — PayPal

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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)

Creating a PayPal account is not a prerequisite for PayPal to collect a person's Personal Information; data collection applies to any use of covered services.

Clause Stability Stable

Changes

Months Monitored

Jul 10, 2026

First Seen

Jul 10, 2026

Last Seen

This clause type exists across 4198 other provisions on other platforms.

Consumer impact (what this means for users)

Using PayPal-powered services without an account still subjects the reader to PayPal's Personal Information collection.

How other platforms handle this

Instacart Medium

you may refer a friend to Instacart or send an Instacart gift delivery or gift card to someone. In these cases, we collect the recipient's name, email, and delivery address, as applicable.

Anthropic Medium

We collect information about your use of the Services, such as the dates and times of access, browsing history, search, information about the links you click and about third-party applications...

GitHub Medium

For paid subscriptions, we collect details like name, billing address, and payment specifics.

See all platforms with this clause type →

Monitoring

PayPal has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD

"
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...

— 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

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 9, 2026

Record ID

CA-P-020065

Document ID

CA-D-00045

Evidence Provenance

Source URL

https://www.paypal.com/us/legalhub/privacy-full

Wayback Machine

View archived versions →

Content hash (SHA-256)

323a171a636780ae11796995ce3314342502ac7d4a05f085477133259b344eb1

Analysis generated

July 9, 2026 04:08 UTC

Methodology

summarize_document-v8

Evidence

✓ Snapshot stored ✓ Hash verified

Citation Record

Entity: PayPal
Document: PayPal Privacy Statement
Record ID: CA-P-020065
Captured: 2026-07-09 04:08:48 UTC
SHA-256: 323a171a636780ae…
URL: https://conductatlas.com/platform/paypal/paypal-privacy-statement/provision/CA-P-020065/collection-of-personal-information-from-non-account-holders/
Accessed: July 12, 2026

Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Classification

Severity

Medium

Other risks in this policy

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Frequently Asked Questions

What does PayPal's Collection of Personal Information From Non-Account Holders clause do?

Creating a PayPal account is not a prerequisite for PayPal to collect a person's Personal Information; data collection applies to any use of covered services.

How does this clause affect you?

Using PayPal-powered services without an account still subjects the reader to PayPal's Personal Information collection.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 300 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.