Venmo shares your personal and financial information with PayPal's affiliated companies and with outside service providers for purposes including payment processing, fraud prevention, and marketing.
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 agreement authorizes sharing of user data, including financial transaction history, bank account identifiers, and personal identifiers, across the PayPal corporate family and with third-party vendors, which extends the effective data environment beyond Venmo itself.
Interpretive note: The scope of 'marketing' data sharing and whether it constitutes CCPA 'sharing' for cross-context behavioral advertising purposes depends on the specific third-party arrangements in place, which are not fully detailed in the agreement text.
Under this provision, personal identifiers, bank account information, and transaction history may be shared with PayPal affiliates and third-party service providers including marketing partners; users in California have rights under the CCPA to request disclosure of the specific categories of personal information shared and to opt out of sharing for cross-context behavioral advertising purposes.
How other platforms handle this
By using the Services, you authorize Affirm to share your information, including personal information and information related to your transactions and use of the Services, with merchants, service providers, and other third parties as further described in our Privacy Policy.
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
We may receive information, including the following, from third party sources and combine it with information we already directly collect from you. We will handle the information in accordance with this Privacy Policy. Game, social media, or other information, from those third parties or services yo...
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"When you use the Venmo services, we share your information with other companies in the PayPal family of companies to help operate our services, prevent fraud, and offer you products and services. We also share your information with service providers that help us operate the Venmo services, including companies that assist with identity verification, payment processing, fraud prevention, customer service, and marketing.— Excerpt from Venmo's Venmo User Agreement
1) REGULATORY LANDSCAPE: Data sharing practices described in this provision interact with the Gramm-Leach-Bliley Act (GLBA), which requires financial institutions to provide privacy notices and opt-out rights for sharing with non-affiliated third parties. The CCPA requires disclosure of categories of personal information shared and grants California residents the right to opt out of the sale or sharing of personal information. The FTC Act Section 5 is relevant to representations about data sharing practices. FinCEN regulations impose limitations on how transaction data may be shared in ways inconsistent with BSA obligations. 2) GOVERNANCE EXPOSURE: Medium. The breadth of the sharing authorization, which encompasses PayPal affiliates, payment processors, fraud prevention services, and marketing partners, creates a wide data environment that requires mapping under CCPA and GLBA compliance frameworks. The inclusion of marketing partners as authorized recipients of user data is the most operationally significant element for CCPA 'sharing' analysis. 3) JURISDICTION FLAGS: California residents have the most significant rights under CCPA and the California Financial Information Privacy Act (CFIPA), which imposes additional restrictions on sharing financial information with affiliates. Vermont, Maine, and other states with active consumer privacy statutes may impose notice and opt-out obligations. EU and UK users are not subject to this agreement as it is US-specific. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party service providers receiving user data under this authorization should be covered by data processing agreements that address GLBA safeguards requirements and, where applicable, CCPA service provider obligations. Procurement teams should verify that marketing partners receiving data under this authorization are operating under appropriate contractual constraints. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain a current data inventory mapping which categories of personal information are shared with which categories of third parties, to support CCPA disclosure obligations and GLBA annual privacy notice requirements. CCPA opt-out signals (including Global Privacy Control) should be evaluated against current data sharing practices with marketing partners.
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The agreement authorizes sharing of user data, including financial transaction history, bank account identifiers, and personal identifiers, across the PayPal corporate family and with third-party vendors, which extends the effective data environment beyond Venmo itself.
Under this provision, personal identifiers, bank account information, and transaction history may be shared with PayPal affiliates and third-party service providers including marketing partners; users in California have rights under the CCPA to request disclosure of the specific categories of personal information shared and to opt out of sharing for cross-context behavioral advertising purposes.
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