Cash App
Weighted across nine legal categories. Lower is worse.
Executive summary
This document is a comprehensive Privacy Notice rather than a full Terms of Service, focusing heavily on data collection, usage, and consumer rights. While it offers strong statutory compliance features like opt-outs and data portability, it relies on browsewrap consent, permits indefinite post-closure data retention, and contains broad clauses for AI training and third-party advertising sharing.
Category breakdown
5 of the nine categories are not addressed by this document, so they are left out rather than scored.
Acceptance of Terms & Scope
Contract formation and service boundaries
Consent is obtained via browsewrap language implying agreement through mere use or continued interaction, lacking explicit clickwrap acknowledgment or a plain-language summary.
Key findings
- Implied consent through use
- No explicit clickwrap
- Scope limited to data practices
Evidence from the document
By using Cash App you consent to these data practices.
By continuing to interact with our Services, you are consenting to the practices described in this Privacy Notice.
Recommendations
- Implement explicit clickwrap 'I agree' buttons
- Provide a plain-language summary table
User Accounts
Registration, suspension, and termination
Account closure is permitted, but the company reserves broad, indefinite retention rights post-closure without mentioning data export options or an appeal process for account restrictions.
Key findings
- Indefinite post-closure retention
- No data export mentioned
- No appeal/cure process detailed
Evidence from the document
Even after you close your account, we can retain information about you and any transactions or Services in which you may have participated for a period of time that is consistent with certain criteria...
Recommendations
- Clarify data export options pre-closure
- Specify termination triggers and human review processes
Data Privacy
Data collection, usage, and protection
Offers robust consumer rights (access, delete, portability, opt-outs) and complies with state privacy frameworks, but grants overly broad licenses for AI training and extensive third-party ad sharing.
Key findings
- CCPA/GDPR-style rights honored
- GPC signal processing supported
- Broad AI training clause present
- Extensive advertising partner sharing
Evidence from the document
We may collect, use and share information about you for the following reasons: ... Improving, personalizing and facilitating your use of our Services, content and applications, including by training artificial intelligence (AI) and other machine learning models
To opt out of the “sharing” of your personal information for cross-context behavioral advertising, click on the “Your Privacy Choices” link in the footer of our website.
Recommendations
- Narrow AI training scope to non-personalized/internal use only
- Clarify security breach notification timelines and liability limits
Modification of Terms
How agreements can be changed
Provides advance notice for material changes and allows account cancellation, but relies on continued use for consent and lacks a formal changelog or fixed notice period.
Key findings
- Reasonable prior notice promised
- Continued use deemed acceptance
- No version archive/changelog
Evidence from the document
We will provide you with reasonable prior notice of material changes in how we use your information... If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Privacy Notice.
Recommendations
- Specify exact advance notice period (e.g., 30 days)
- Maintain dated version archive
- Avoid retroactive application to accrued claims
Ex-TerCo provides automated analysis of legal documents for informational purposes. This is not legal advice. Terms can change at any time.