Sharing with Advertising and Analytics Partners

What it is

The policy authorizes sharing of user personal information with service providers, business partners, advertising partners, and analytics providers, with advertising partners specifically described as receiving information to deliver targeted advertisements.

Why it matters (compliance & governance perspective)

This provision authorizes disclosure of personal information, which may include financial account data, device identifiers, and behavioral data, to advertising partners for targeted advertising purposes, a practice that may constitute sale or sharing under CCPA and that engages GLBA's restrictions on sharing nonpublic personal information with nonaffiliated third parties.

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Change history

Consumer impact (what this means for users)

Under this provision, Acorns may share personal information with advertising partners for targeted advertising and with analytics providers for usage analysis. The agreement does not in this provision specify which categories of personal information are shared with advertising partners, and the distinction between service providers and third parties under CCPA, which determines opt-out rights, is not fully delineated in this clause.

What you can do

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: Sharing personal information with advertising and analytics partners engages CCPA's opt-out-of-sale and opt-out-of-sharing for cross-context behavioral advertising provisions, enforced by the California Privacy Protection Agency and California Attorney General. Under GLBA, sharing nonpublic personal information with nonaffiliated third parties for marketing purposes requires a prior opt-out opportunity to be provided to consumers; whether advertising partners qualify as nonaffiliated third parties under GLBA requires entity-specific assessment. FTC Act standards apply to accuracy and completeness of disclosures about third-party data sharing. 2) GOVERNANCE EXPOSURE: High. Sharing financial services consumer data with advertising partners creates concurrent obligations under both GLBA and CCPA, which have overlapping but distinct opt-out frameworks. Failure to provide GLBA-compliant opt-out notices before sharing with advertising partners, or failure to honor CCPA opt-out-of-sharing requests, represents material regulatory exposure. 3) JURISDICTION FLAGS: California residents have an operative right to opt out of sharing for cross-context behavioral advertising under CPRA, independent of whether sharing constitutes a sale. Businesses subject to GLBA must provide annual privacy notices and opt-out opportunities before sharing nonpublic personal information with nonaffiliated third parties for marketing. 4) CONTRACT AND VENDOR IMPLICATIONS: Data sharing agreements with advertising and analytics partners should be reviewed to confirm whether those partners are structured as service providers with contractual use restrictions or as independent third parties, as this classification determines CCPA obligations and GLBA treatment. Agreements should include provisions restricting advertising partners from using received data for purposes beyond those disclosed in the privacy policy. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that GLBA privacy notices and opt-out mechanisms are current and that advertising partner sharing is within the scope of disclosed and properly noticed information sharing categories. CCPA opt-out-of-sharing mechanisms should be tested for functionality, and Global Privacy Control signal honoring should be verified for California users.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Financial and Account Data Collection high
• Device, Behavioral, and Geolocation Data Collection medium
• California Consumer Privacy Act Rights medium
• Children's Data and Acorns Early Product medium
• Data Retention low
• Use of Personal Information for Marketing low