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.
How other platforms handle this
California law gives residents the right to know what personal information we collect, use, share or sell; to delete personal information under certain circumstances; to opt-out of the sale or sharing of their personal information; to correct inaccurate personal information; to limit the use and dis...
Changes to this Privacy Notice
If you are a California resident, you have the right to opt out of the sale or sharing of your personal information. You also have the right to know what personal information we have collected about you, the right to delete your personal information, the right to correct inaccurate personal informat...
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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 Venmo 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. The CFPB and FTC both have enforcement authority over GLBA compliance for Venmo's category of financial service provider. The interaction between GLBA's joint marketing exception and CCPA's sharing opt-out requirements creates a complex compliance matrix that requires ongoing monitoring. 2) GOVERNANCE EXPOSURE: Medium. GLBA compliance is a baseline requirement for Venmo as a financial service provider. The primary exposure areas are: (a) ensuring that the annual privacy notice delivery requirement is satisfied; (b) confirming that opt-out mechanisms function correctly and within required processing timelines; and (c) maintaining documentation that joint marketing partners satisfy GLBA's contractual requirements for that exception. 3) JURISDICTION FLAGS: GLBA applies nationwide. Vermont's financial privacy law restricts affiliate sharing more broadly than federal GLBA and may require opt-in rather than opt-out for certain sharing categories. California's CCPA imposes additional requirements on financial data sharing beyond GLBA's scope. 4) CONTRACT AND VENDOR IMPLICATIONS: Joint marketing partner contracts must include the GLBA-required contractual provisions limiting use of shared financial data to the joint marketing purpose. Non-affiliated third-party marketing data sharing arrangements must be structured to accommodate consumer opt-out requests and maintain suppression lists. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that annual GLBA privacy notice delivery is documented and current; confirm that opt-out processing timelines comply with Regulation P requirements; assess Vermont law applicability for Vermont-resident users; and review whether CCPA's broader 'sharing' opt-out right covers data categories also subject to GLBA opt-out to ensure both frameworks are satisfied simultaneously.
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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.
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