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The policy discloses that targeting cookies collect user interaction data across websites to build interest-based profiles, which are used for personalized advertising and may be shared with third-party advertisers for ad performance measurement and profile-based ad delivery.
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 describes cross-context behavioral advertising practices involving profile construction from cross-site tracking data and sharing of that data with third-party advertisers. These practices fall within the categories of data use subject to opt-out rights under CCPA/CPRA and may engage FTC guidance on online behavioral advertising.
The updated terms restructure how SoFi discloses and collects consent for tracking technologies. Previously, SoFi stated that non-selection of preferences constituted acceptance of tracking. The updated version creates distinct cookie categories (Functional, Performance, Targeting, Strictly Necessary) and establishes a Privacy Preference Center allowing you to individually toggle Performance and Targeting cookies on or off. Strictly Necessary Cookies remain non-optional and cannot be disabled, as the updated terms state these are necessary for website functionality. You can manage individual cookie category preferences through the Privacy Preference Center interface before or after initial site visit.
View change record →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 →Under this clause, the agreement authorizes the use of targeting cookies to track user behavior across websites, build interest profiles, and share that data with advertisers for personalized ad delivery and performance measurement. Users who activate the targeting cookie opt-out in SoFi's Privacy Preference Center can decline this category of data collection and sharing.
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"Targeting cookies track users' actions and are used to identify users between different websites. Targeting cookies collect user information and use it to build a profile of users' interests and then show personalized ads for that specific user. Targeting cookies help to attract customers with targeted ads. The information the cookies gather about you can be shared with other advertisers to measure the performance of their advertisements and may be used to build a profile to deliver personalized ads.Excerpt from SoFi's Privacy Notice
1) REGULATORY LANDSCAPE: This provision engages CCPA/CPRA provisions governing cross-context behavioral advertising and the sell/share opt-out obligations for businesses that share personal information with third parties for advertising purposes. The FTC's guidance on online behavioral advertising, including principles for transparency and consumer control, is also relevant. The California Privacy Protection Agency and California Attorney General hold enforcement authority. State privacy laws in other jurisdictions with similar behavioral advertising opt-out requirements may also apply. 2) GOVERNANCE EXPOSURE: Medium. The disclosure that targeting cookie data may be shared with advertisers for profile construction and ad performance measurement describes practices that are subject to opt-out requirements under CCPA/CPRA. The adequacy of the opt-out mechanism and whether it effectively prevents all described sharing upon activation are operational compliance questions that require technical audit. 3) JURISDICTION FLAGS: California residents have clear statutory opt-out rights for cross-context behavioral advertising under CCPA/CPRA. Residents of other states with enacted comprehensive privacy laws may have similar rights. Users in EU/EEA jurisdictions would be subject to GDPR consent requirements for this category of processing, though the document appears scoped to U.S. users and does not address GDPR applicability. 4) CONTRACT AND VENDOR IMPLICATIONS: Sharing targeting cookie data with third-party advertisers creates vendor contract review obligations to confirm that data use restrictions are contractually established and enforced. The disclosure that shared data may be used by other advertisers to build profiles raises questions about secondary use restrictions in third-party agreements. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the technical implementation of the targeting cookie opt-out to confirm it prevents both data collection and downstream sharing upon activation. The list of advertisers and analytics partners receiving this data should be maintained in an updated data map and disclosed in the full Online Privacy Policy. Global Privacy Control signal recognition should be assessed for California compliance.
This provision describes cross-context behavioral advertising practices involving profile construction from cross-site tracking data and sharing of that data with third-party advertisers. These practices fall within the categories of data use subject to opt-out rights under CCPA/CPRA and may engage FTC guidance on online behavioral advertising.
Under this clause, the agreement authorizes the use of targeting cookies to track user behavior across websites, build interest profiles, and share that data with advertisers for personalized ad delivery and performance measurement. Users who activate the targeting cookie opt-out in SoFi's Privacy Preference Center can decline this category of data collection and sharing.
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