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The policy states that Venmo collects personal information from data brokers, advertising networks, data analytics providers, credit reporting agencies, and government entities, in addition to disclosing user data to third-party service providers and partners involved in business operations.
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 establishes that personal information flows both to and from advertising networks and data brokers, creating a bidirectional data exchange relationship with these third-party categories. While the policy states Venmo does not sell or share personal information for cross-context behavioral advertising, the disclosure of data sharing with advertising networks may require evaluation under CCPA definitions of sharing.
Interpretive note: The policy asserts no sale or sharing for behavioral advertising while disclosing relationships with advertising networks; whether these relationships constitute sharing under CCPA depends on their contractual structure, which is not disclosed in this policy.
Under this clause, Venmo discloses personal information to and receives it from advertising networks, data brokers, and analytics providers as part of its stated business operations. The policy separately states that Venmo does not sell or share personal information for cross-context behavioral advertising, but the operational relationship with advertising networks is disclosed in the data source and recipient lists.
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"We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, payment networks and financial institutions.Excerpt from Venmo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages CCPA definitions of selling and sharing personal information, enforced by the California Privacy Protection Agency. The FTC Act governs unfair or deceptive data practices. State data broker registration laws in California, Vermont, and Texas may apply to Venmo's receipt of data from data brokers. GLBA requirements govern financial data shared with or received from financial institutions. 2) GOVERNANCE EXPOSURE: Medium. The policy's simultaneous assertion that it does not sell or share for behavioral advertising and its disclosure of advertising network relationships may require careful evaluation under CCPA's definition of sharing, which encompasses targeting of advertising based on consumer activity across websites. 3) JURISDICTION FLAGS: California creates heightened exposure given CCPA's broad definition of sharing and the California Privacy Protection Agency's enforcement authority. Vermont's data broker registration requirements may apply depending on the nature of data received from data broker sources. 4) CONTRACT AND VENDOR IMPLICATIONS: The policy states that service provider contracts restrict data use to services performed for Venmo, but does not specify whether advertising network relationships are structured as service provider agreements or as separate data sharing arrangements. This distinction is material under CCPA. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the advertising network data flows are accurately characterized under CCPA's definitions of selling and sharing, confirm that data broker data sources are documented in data mapping records, assess whether data broker registration obligations in California and Vermont apply, and evaluate whether the policy's non-sale assertion is supported by the contractual structure of advertising network relationships.
This provision establishes that personal information flows both to and from advertising networks and data brokers, creating a bidirectional data exchange relationship with these third-party categories. While the policy states Venmo does not sell or share personal information for cross-context behavioral advertising, the disclosure of data sharing with advertising networks may require evaluation under CCPA definitions of sharing.
Under this clause, Venmo discloses personal information to and receives it from advertising networks, data brokers, and analytics providers as part of its stated business operations. The policy separately states that Venmo does not sell or share personal information for cross-context behavioral advertising, but the operational relationship with advertising networks is disclosed in the data source and recipient lists.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Venmo.