Federal law requires Venmo to tell you how it shares your financial data and gives you limited rights to opt out of certain types of sharing, particularly sharing with non-Venmo companies for marketing purposes.
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
The GLBA notice defines the scope of your federal opt-out rights regarding financial data sharing; it also discloses that several categories of sharing, including sharing for joint marketing and everyday business purposes, cannot be opted out of under federal law.
Interpretive note: The specific categories of sharing that qualify for GLBA exceptions versus those subject to opt-out rights cannot be fully assessed without knowing the complete list of Venmo's third-party sharing arrangements and their contractual structures.
The terms establish that users have a federal right to opt out of sharing with non-affiliated third parties for marketing purposes under GLBA, but that sharing for Venmo's everyday business operations, joint marketing arrangements, and certain affiliate purposes proceeds without an opt-out right under federal law.
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"As a financial company, we are required to explain how we share your personal financial information. Federal law gives you the right to limit only certain sharing: sharing for affiliates' everyday business purposes; sharing with affiliates to market to you; and sharing with non-affiliates to market to you. Federal law does not give you the right to limit all sharing.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: GLBA and its implementing Regulation P, enforced by the CFPB, require financial institutions to provide annual privacy notices and honor consumer opt-out requests for sharing with non-affiliated third parties for marketing.
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The GLBA notice defines the scope of your federal opt-out rights regarding financial data sharing; it also discloses that several categories of sharing, including sharing for joint marketing and everyday business purposes, cannot be opted out of under federal law.
The terms establish that users have a federal right to opt out of sharing with non-affiliated third parties for marketing purposes under GLBA, but that sharing for Venmo's everyday business operations, joint marketing arrangements, and certain affiliate purposes proceeds without an opt-out right under federal law.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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