📄 Policy Information

April 29, 2024
PayPal Holdings, Inc.
PayPal, Inc.

⚠️ Data Sensitivity: Tier 2 (Highly Sensitive)

Payment apps process financial data, transaction history, bank account information, and SSN. This data requires heightened privacy protections under our methodology.

Privacy Score Breakdown

Data Collection Scope 18/100

Collects extensive PII, SSN, geolocation, biometric, bank data, social media

Third-Party Sharing 15/100

Shares for marketing, analytics; third-party connections lose Venmo protections

Data Retention 20/100

No specific timeframes; continues sharing after you're no longer a customer

User Control 25/100

Privacy controls exist but buried; defaults expose data publicly

Transparency 30/100

FTC found notices inadequate; cannot respond to Do Not Track

⚖️ Regulatory Enforcement History

FTC Settlement (2018) - Privacy Misrepresentations

The FTC alleged that Venmo violated Section 5 of the FTC Act and the Gramm-Leach-Bliley Act's Privacy and Safeguards Rules.

Key findings:

  • Misrepresented information security as "bank-grade"
  • Failed to provide clear privacy notice about public transactions
  • Did not properly explain that transactions were visible to anyone

Plaid Inc. Class Action Settlement ($58M) - 2024

Plaid, used by Venmo for account linking, agreed to pay $58 million for accessing consumers' private banking data without consent.

When users entered login credentials, Plaid allegedly collected transaction history, investment data, salary information, and personal identifying information beyond what was necessary.

📊 Data Collection Scope (Cited)

Extensive Personal Information

Venmo collects a comprehensive range of personal data:

"Venmo collects a host of personal data including your name, address, email, telephone number, information about what device you are using to access Venmo, financial information (your bank account information), SSN (or other governmental issued verification numbers), geolocation information (your location), and social media information if you decide to connect your Venmo account with social media such as Twitter, FourSquare, and Facebook."

Biometric and Health Data

According to Common Sense Privacy's evaluation:

"Venmo collects: personally identifiable information (PII), geolocation data, biometric or health data, and interactions, behaviors, or usage analytics data."
Source: Common Sense Privacy Report - Venmo (Rating: Warning - 68%)

Teen Account Data Collection

For Teen Accounts, Venmo claims minimized collection:

"We will not collect more information about you than what is required to use the Teen Account."
Source: Venmo Privacy Statement - Teen Accounts section

👥 Third-Party Sharing (Cited)

Third-Party Marketing and Promotional Purposes

Common Sense Privacy's analysis found:

"Information may be shared with third parties for their own promotional or marketing purposes."

Third-Party Connections Lose Venmo Protections

When you connect Venmo to other services, your data is subject to their policies:

"Data shared with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices... This data may in turn be shared with certain other parties, including the general public, depending on the account's or platform's privacy practices."
Source: Venmo Privacy Statement - Third-Party Connections

Continued Sharing After Account Closure

Your data doesn't stop being shared when you leave:

"When you are no longer a customer, we continue to disclose your information as described in this Statement."

🌐 Public Data Exposure (Cited)

Transactions Public by Default

Venmo's default privacy settings expose your financial activities:

"By default, many Venmo transactions are visible to your friends and even their friends."

API Access to Public Data

Your public data is programmatically accessible:

"Public information may also be seen, accessed, reshared or downloaded through Venmo's APIs or third-party services that integrate with our products."
Source: Venmo Privacy Statement - Public Information

Real-World Privacy Breach Via API

The consequences of public-by-default data have been demonstrated:

"A 2018 Mozilla analysis of over 207 million public transactions revealed users' shopping habits, gas stations, restaurants, and daily routines. The researcher even identified drug dealers and tracked individuals' movements through transaction metadata and linked social media accounts."

🕐 Data Retention & Tracking (Cited)

Vague Retention Policy

Common Sense Privacy found:

"Retention policy available with exceptions. Data deleted when no longer necessary. User data deleted upon account termination. Timeframe for deletion not specified."

Do Not Track Ignored

Venmo does not honor privacy signals:

"Company cannot respond to 'Do Not Track' mechanisms."

Behavioral Profiling

Your data is used for targeted advertising:

"Personalized advertising displayed. Data profiles created for targeted ads. Third-party data collection for tracking purposes."

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