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By providing a mobile phone number, users consent to PayPal and its affiliates contacting them via autodialed or prerecorded calls and texts for account servicing, fraud investigation, and debt collection. Marketing calls and texts require separate prior express written consent.
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 that providing a mobile phone number to PayPal constitutes consent to autodialed and prerecorded contact for three stated purposes, with marketing communications subject to a higher prior express written consent standard. Users may withdraw consent through account settings, customer support, a specific phone number, or by replying STOP.
⚠ Autodialed and prerecorded calls and texts for account servicing, fraud investigation, and debt collection will continue as stated in the agreement
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"If you provide us your mobile phone number, you agree that PayPal and its affiliates may contact you at that number using autodialed or prerecorded message calls or text messages to: (i) service your PayPal branded accounts, (ii) investigate or prevent fraud, or (iii) collect a debt. We will not use autodialed or prerecorded message calls or texts to contact you for marketing purposes unless we receive your prior express written consent. We may share your mobile phone number with service providers with whom we contract to assist us with the activities listed above, but we will not share your mobile phone number with third parties for their own purposes without your consent.Excerpt from PayPal's User Agreement
1. REGULATORY LANDSCAPE: This provision implicates the Telephone Consumer Protection Act (TCPA), which governs autodialed and prerecorded communications to mobile numbers and requires prior express consent for non-emergency calls. The FTC enforces the Telemarketing Sales Rule, and the FCC enforces TCPA regulations. The distinction between account servicing consent (implied by number provision) and marketing consent (requiring prior express written consent) reflects standard TCPA compliance practice, though the adequacy of consent obtained through terms acceptance rather than dedicated opt-in may be subject to challenge. 2. GOVERNANCE EXPOSURE: Medium. The provision aligns with standard TCPA compliance structures, distinguishing between operational communications and marketing. However, the characterization of debt collection as a permitted autodialed use warrants review given ongoing FCC and FTC scrutiny of autodialed debt collection practices. 3. JURISDICTION FLAGS: California's TCPA-equivalent statutes and the California Consumer Privacy Act may impose additional consent and disclosure requirements. State-specific autodial and prerecorded call restrictions in states including Florida, Connecticut, and Indiana may create heightened compliance obligations beyond federal TCPA requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: PayPal's stated authority to share mobile phone numbers with contracted service providers for the stated purposes should be evaluated in the context of TCPA agency liability, which may extend to the contracting service providers. Vendor agreements with communication service providers should include appropriate TCPA compliance representations. 5. COMPLIANCE CONSIDERATIONS: The opt-out mechanisms provided (account settings, phone, customer support, STOP reply) should be tested for operational accessibility and response time compliance with TCPA opt-out processing requirements. Internal consent records should be maintained to document the basis for autodialed contact for each user, particularly for debt collection communications.
This provision establishes that providing a mobile phone number to PayPal constitutes consent to autodialed and prerecorded contact for three stated purposes, with marketing communications subject to a higher prior express written consent standard. Users may withdraw consent through account settings, customer support, a specific phone number, or by replying STOP.
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