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The policy states that Venmo does not sell or share personal information, including sensitive personal information, for cross-context behavioral advertising as defined under CCPA, and separately states that CCPA provisions do not apply to financial data governed by GLBA.
This analysis describes what Venmo'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 asserts CCPA non-sale and non-sharing status for all personal information categories while simultaneously invoking the GLBA carve-out for financial data, which may affect the scope of California residents' CCPA deletion, access, and opt-out rights depending on how data categories are classified between financial and non-financial.
Interpretive note: The scope of the GLBA carve-out relative to non-financial data categories Venmo collects, such as geolocation, biometrics, and social web information, is not specified in the policy and may depend on regulatory interpretation.
Under this clause, California residents' CCPA rights to opt out of sale or sharing of personal information are asserted to be inapplicable because Venmo states it does not engage in such practices; however, CCPA access and deletion rights for financial data governed by GLBA are separately carved out, which may limit the scope of actionable CCPA requests for certain data categories.
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"We do not sell or share your Personal Information, including any Sensitive Personal Information. This notice should be read together with Venmo's Privacy Statement and applies to all California residents who visit our Sites or use the Services. These provisions do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law such as the Gramm-Leach-Bliley Act.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages the CCPA and California Privacy Rights Act, enforced by the California Privacy Protection Agency and California Attorney General, and GLBA enforced by the FTC. The tension between CCPA consumer rights and the GLBA carve-out is a recognized area of regulatory complexity; the carve-out applies to data collected and processed pursuant to GLBA, but Venmo also collects non-financial data categories that may not qualify for the carve-out. 2) GOVERNANCE EXPOSURE: Medium. The policy asserts non-sale and non-sharing status, which, if accurate, satisfies CCPA opt-out requirements. However, the scope of the GLBA carve-out relative to non-financial data categories (geolocation, device identifiers, social web information, biometrics) is not specified and may be subject to regulatory challenge. 3) JURISDICTION FLAGS: California creates the primary exposure for this provision. Vermont's financial privacy statute creates separate obligations for Vermont account holders regarding non-affiliate sharing, which the policy addresses through a Vermont-specific carve-out limiting non-affiliate sharing. 4) CONTRACT AND VENDOR IMPLICATIONS: The policy's non-sale assertion depends on the contractual structure of advertising network and data broker relationships. If any such relationships do not qualify as service provider arrangements under CCPA, the non-sale assertion may be subject to challenge by the California Privacy Protection Agency. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the data flow and contractual basis for all advertising network and data broker relationships to support the non-sale and non-sharing assertion, assess whether the GLBA carve-out is correctly applied across all data categories Venmo collects, and monitor California Privacy Protection Agency guidance on the interaction between GLBA and CCPA as it evolves.
This provision asserts CCPA non-sale and non-sharing status for all personal information categories while simultaneously invoking the GLBA carve-out for financial data, which may affect the scope of California residents' CCPA deletion, access, and opt-out rights depending on how data categories are classified between financial and non-financial.
Under this clause, California residents' CCPA rights to opt out of sale or sharing of personal information are asserted to be inapplicable because Venmo states it does not engage in such practices; however, CCPA access and deletion rights for financial data governed by GLBA are separately carved out, which may limit the scope of actionable CCPA requests for certain data …
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