The policy states that it applies to personal information collected from non-Venmo users who receive payments through the Visa+ service, with Venmo receiving recipient name and payment information from Visa and third-party digital wallets for payment processing and matching 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
This provision extends Venmo's data collection and policy scope to individuals who are not Venmo customers but receive payments through Visa+, creating a data controller relationship with non-users who have not directly agreed to Venmo's terms. The legal basis for processing non-user personal data and the notice mechanism provided to those individuals are not specified in the policy.
Interpretive note: The policy does not specify the legal basis for processing non-user recipient data or the notice and rights mechanisms available to those individuals, creating uncertainty about compliance with applicable state and federal privacy frameworks.
Under this clause, individuals who receive Visa+ payments from Venmo users but are not themselves Venmo customers have their name and payment information collected and processed by Venmo under this privacy policy. The policy does not specify how non-user recipients are informed of this data collection or what rights they have to access, correct, or delete their information.
Cross-platform context
See how other platforms handle Visa+ Non-User Data Collection and similar clauses.
Compare across platforms →"This Privacy Statement also applies to all information we collect from non-Venmo users who receive payment from Venmo users through the Visa+ Service (the 'Recipient'). The Visa+ Service enables customers, with an eligible Venmo account, to send and receive money to and from PayPal and third-party Visa+ enabled digital wallets ('Visa+'). In particular, for Visa+ we will receive the Recipient's name and payment information from Visa and third-party Visa+ participating digital wallets for the purpose of processing and matching Visa+ payment transactions between participating digital wallets and Venmo.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages FTC authority over data collection practices affecting consumers who have not established a direct relationship with the collecting entity.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision extends Venmo's data collection and policy scope to individuals who are not Venmo customers but receive payments through Visa+, creating a data controller relationship with non-users who have not directly agreed to Venmo's terms. The legal basis for processing non-user personal data and the notice mechanism provided to those individuals are not specified in the policy.
Under this clause, individuals who receive Visa+ payments from Venmo users but are not themselves Venmo customers have their name and payment information collected and processed by Venmo under this privacy policy. The policy does not specify how non-user recipients are informed of this data collection or what rights they have to access, correct, or delete their information.
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