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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.
How other platforms handle this
The right to withdraw your consent, where processing of Personal Data is based on your consent
Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
When we rely on consent as the legal basis, you have the right to withdraw your consent for data processing at any time.
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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. The California Privacy Protection Agency and California Attorney General enforce these requirements. The mechanism also engages FTC Act Section 5 regarding deceptive practices in consent collection. CCPA requires that opt-out of sale and sharing be a clear and affirmative process; passive opt-in via page abandonment may require evaluation against this standard. 2) GOVERNANCE EXPOSURE: High. The automatic AllowAll trigger upon page abandonment for users who have not interacted with the consent banner creates potential exposure under CCPA opt-out of sale and sharing requirements. If any cookies activated through this mechanism facilitate the sharing of personal information with third-party advertising or analytics partners, this flow may constitute a sale or sharing under CCPA without valid opt-out handling for California residents who passively leave the page. 3) JURISDICTION FLAGS: California creates the highest exposure given CPRA's explicit opt-out of sharing requirements for cross-context behavioral advertising. The CPPA has issued enforcement guidance on consent mechanisms and dark patterns. If SoFi serves EU or UK users on these pages, the mechanism may also engage GDPR and UK GDPR requirements for affirmative consent to non-essential cookies, though the document does not indicate EU-specific user scope for this page. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics vendors receiving data through cookies activated via this mechanism should be assessed to confirm data processing agreements reflect the consent basis asserted. If the consent mechanism is later determined to be insufficient under CCPA, downstream vendor agreements may require amendment to reflect corrected consent flows. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether the AllowAll trigger upon page abandonment satisfies CCPA opt-out of sharing requirements for unauthenticated California users. The OneTrust implementation should be reviewed to confirm that the consent state recorded reflects the user's actual interaction, and that no sale or sharing of personal information occurs for users who have not affirmatively consented. A consent mechanism audit specific to California-resident user flows is warranted.
Regulatory citations, enforcement risk, and due diligence action items.
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
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 295 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by SoFi.