If a user navigates away from the page, closes the tab, or switches applications without interacting with the cookie consent banner, and has not enabled Global Privacy Control in their browser, the site automatically opts the user into all cookie categories via OneTrust's AllowAll function.
This analysis describes what SoFi'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 a passive consent mechanism that triggers full cookie opt-in upon page abandonment for users who have not explicitly engaged with the consent banner, which may require evaluation under CCPA and CPRA requirements for opt-out of sale and sharing of personal information for California residents.
Interpretive note: Whether this mechanism constitutes a violation of CCPA opt-out of sharing requirements depends on enforcement interpretation and whether the cookies activated facilitate sale or sharing as defined under CCPA; this is an operational observation based on the page source code rather than the policy text itself.
The updated Privacy Notice explicitly discloses that SoFi collects user information through cookies, pixels, and other tracking technologies and shares this data with social media, advertising, and analytics partners. Previously, the policy described these practices in more general language. Under the revised terms, continued use of SoFi's website constitutes acceptance of these tracking and data-sharing practices unless the user actively makes selections in the Privacy Preference Center. You can use the preference center to opt out of optional tracking technologies, though strictly necessary cookies cannot be disabled.
View change record →The updated privacy notice explicitly discloses that SoFi uses pixels and tracking technologies to collect information about your actions and preferences, and shares this data with social media, advertising, and analytics partners. The revised consent interface distinguishes between strictly necessary cookies (which cannot be disabled) and optional cookies for performance and targeting purposes (which require affirmative consent). The terms state that if you do not make a selection, you agree to use of these technologies; you can opt out by toggling the button that appears to the right of each optional cookie category.
View change record →The updated terms establish a more permissive consent model for tracking technologies. Previously, the policy stated that users could 'choose not to allow some types of cookies' (opt-in structure). The revised language now states 'If you do not make a selection, you agree to our use of these technologies' (opt-out structure). This means that continued use of the website without affirmative rejection constitutes acceptance of cookies, pixels, and data sharing with advertising and analytics partners. The updated terms also explicitly disclose that SoFi shares collected information with 'social media, advertising, and analytics partners,' providing more specificity about data sharing destinations. You can decline the Privacy Preference Center or decline all optional tracking technologies through the updated preference settings.
View change record →This new high-severity provision implements automatic cookie opt-in when users leave the page without interacting with consent controls, unless GPC is enabled, raising significant privacy compliance concerns.
View full change record →Under this mechanism, users who leave the SoFi page without clicking the consent banner will have all cookie categories, including advertising and analytics cookies, activated. Users who enable Global Privacy Control in their browser will have all non-essential cookies rejected instead.
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"function optUserIntoCookiesIfCTAsNotClicked() { if (document.visibilityState !== 'hidden') { return; } const userClickedCTA = OneTrust.IsAlertBoxClosed(); const isGPCEnabled = navigator.globalPrivacyControl === true; if (!userClickedCTA && !isGPCEnabled) { window.OneTrust.AllowAll(); } else if (isGPCEnabled) { window.OneTrust.RejectAll(); } }Excerpt from SoFi's Privacy Notice
1) REGULATORY LANDSCAPE: This consent mechanism engages the California Consumer Privacy Act as amended by the CPRA, specifically provisions governing opt-out of sale and sharing of personal information for cross-context behavioral advertising.
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This provision establishes a passive consent mechanism that triggers full cookie opt-in upon page abandonment for users who have not explicitly engaged with the consent banner, which may require evaluation under CCPA and CPRA requirements for opt-out of sale and sharing of personal information for California residents.
Under this mechanism, users who leave the SoFi page without clicking the consent banner will have all cookie categories, including advertising and analytics cookies, activated. Users who enable Global Privacy Control in their browser will have all non-essential cookies rejected instead.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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