Clearpay

Overview

Clearpay is a buy-now-pay-later (BNPL) payment service that allows consumers to split purchases into installments. Its scripts appear on e-commerce product pages and checkout flows when retailers integrate Clearpay as a payment option. The widget serves a dual purpose: displaying installment messaging on product pages (to influence purchase decisions) and processing the BNPL transaction at checkout. Clearpay operates primarily in the UK and Australia; the identical service trades as Afterpay in the US and other markets.

What This Script Does

Clearpay loads its widget script from js.afterpay.com or portal.clearpay.co.uk (the platforms share infrastructure). The script performs:

• Product page messaging: Renders installment pricing callouts ("4 payments of £X") adjacent to the product price, using the product price passed to the script as a parameter
• Eligibility indicator: May perform a soft eligibility check using device signals and any available Clearpay account cookies to display personalized messaging for returning Clearpay customers
• Checkout processing: At checkout, the script initiates the Clearpay payment flow, redirecting the consumer to Clearpay's authorization page and returning a payment token upon approval

Cookies set include session cookies for the payment flow state and potentially persistent cookies for recognized Clearpay account holders (linking the browser to a known Clearpay account for returning customer messaging). Payment transaction data (order value, merchant ID, consumer identity for approved loans) is transmitted to Clearpay/Afterpay's servers.

No behavioral advertising cookies or cross-site profiling is performed by the widget script itself. The persistent cookie for account recognition is functional — it enables the "returning customer" experience.

Consent & Compliance

Clearpay's checkout processing functionality is strictly necessary for completing the payment transaction and falls within the ePrivacy Directive's exemption for cookies "strictly necessary in order to provide an information society service explicitly requested by the subscriber or user." A user who selects Clearpay at checkout has explicitly requested the service.

Product page installment messaging scripts that load on all product pages (before the user has selected Clearpay) are a closer question — they set cookies for account recognition even for visitors who may never use Clearpay. These pre-checkout scripts are more accurately characterized as functional/marketing rather than strictly necessary.

Under GDPR, payment transaction data is processed under Article 6(1)(b) (contract performance). Under CCPA/CPRA, payment data is processed as a service provider and is exempt from sale/sharing restrictions.

The consent category is functional — payment processing is user-initiated; product page messaging scripts sit closer to functional with minor marketing characteristics.

Should You Block This Without Consent?

Conditional. Clearpay scripts loaded at checkout for active payment processing are functionally necessary and should not be blocked. Product page installment messaging scripts that load universally — setting account recognition cookies before any user selection — should be treated as functional and disclosed in the privacy notice, with consideration given to deferring load until user interaction with the payment option.