Affiliate and Third-Party Data Sharing

What it is

Venmo shares your personal and financial data with PayPal companies, marketing partners, analytics firms, and financial institutions, as well as with law enforcement when required.

Why it matters (compliance & governance perspective)

The terms authorize sharing of personal and financial data with a broad range of entities including marketing partners, which under GLBA requires that users be given an opt-out right for non-affiliated third-party marketing sharing.

Consumer impact (what this means for users)

Personal and financial data collected by Venmo may be shared with PayPal affiliates, marketing partners, and analytics providers, potentially enabling targeted advertising and cross-platform profiling; users may have GLBA opt-out rights regarding non-affiliated third-party marketing sharing depending on specific data categories and partner relationships.

What you can do

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: GLBA Regulation P requires financial institutions to provide consumers with the right to opt out of sharing nonpublic personal financial information with non-affiliated third parties for marketing purposes. The CFPB enforces Regulation P. The CCPA/CPRA requires disclosure of categories of third parties with whom personal information is shared and grants California residents the right to opt out of sale or sharing for cross-context behavioral advertising. The FTC Act applies to deceptive representations about data sharing practices. 2) GOVERNANCE EXPOSURE: High. The breadth of authorized sharing categories, including marketing partners and analytics providers, implicates both GLBA opt-out requirements and CCPA sharing opt-out rights. Whether specific sharing arrangements constitute 'sale' or 'sharing' under CCPA requires case-by-case analysis of data flows and compensation structures. 3) JURISDICTION FLAGS: California creates the most significant exposure due to CCPA/CPRA's definition of 'sharing' for cross-context behavioral advertising, which does not require monetary consideration to trigger opt-out rights. Vermont's financial privacy law may impose stricter restrictions on affiliate sharing than federal GLBA allows. European data protection law is not applicable as Venmo is a U.S.-only service. 4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with each marketing partner and analytics provider should specify permitted uses, sub-processing restrictions, and security obligations consistent with GLBA Safeguards Rule and CCPA service provider requirements. Any revenue-sharing or data-for-services arrangements with marketing partners should be assessed for CCPA 'sale' classification. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit all active third-party data sharing relationships to confirm alignment with disclosed categories; verify that GLBA opt-out notices are delivered at account opening and annually; confirm that the CCPA 'Do Not Sell or Share' mechanism covers all sharing categories described in the policy; and review whether analytics provider relationships meet CCPA service provider or contractor exemption requirements.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Default Public Transaction Feed high
• Financial and Personal Data Collection high
• Location Data Collection medium
• Cookie and Tracking Technology Use medium
• California Consumer Privacy Rights (CCPA/CPRA) medium
• GLBA Financial Privacy Notice and Opt-Out medium

Related Analysis

• Meta Removed 438 Sentences From Its Privacy Policy. Here Is What Disappeared.

  ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.

• 23andMe Is Bankrupt. What Happens to Your DNA Now?

  Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.