The policy authorizes ADP to share personal data including bank account information with business partners in the context of referral validation and related commercial transactions, subject to the condition that the individual has purchased from, interacted with, or authorized sharing with that partner.
This analysis describes what ADP'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
This provision authorizes disclosure of bank account information to third-party business partners for referral validation purposes, which may engage financial data protection requirements under the Gramm-Leach-Bliley Act and applicable state financial privacy statutes depending on the nature of the business relationship.
Interpretive note: Whether GLBA applies to ADP in this context depends on whether ADP qualifies as a financial institution under the statute's definition, which is not established by this document alone.
ADP deleted the cookie preference management tool that previously allowed users to understand and control which cookies were placed on their devices, including functional, analytics, and advertising cookies. The removal eliminates the transparency mechanism through which users could consent to or opt out of different cookie categories. The practical effect depends on whether ADP has replaced this functionality elsewhere or whether cookies continue to be placed without equivalent granular user control.
View change record →Under this clause, ADP may share an individual's contact information and bank account information with business partners for referral validation where the individual has interacted with or been referred by that partner. The policy does not specify the technical or contractual safeguards applied to bank account information shared with business partners in this context.
Cross-platform context
See how other platforms handle Business Partner Data Sharing Including Bank Account Information and similar clauses.
Compare across platforms →"Our business partners, but only to the extent you have purchased product or service from such partner, interacted with such partner, or otherwise authorized the sharing. For example, if you are referred to ADP from a business partner website, we may provide that partner with your contact information and certain economic and financial information, such as bank account information, to validate the referral.Excerpt from ADP's Privacy Statement
REGULATORY LANDSCAPE: Disclosure of bank account information to third parties may engage the Gramm-Leach-Bliley Act (GLBA) if ADP is a financial institution under that statute's definition, requiring notice and opt-out rights for sharing with non-affiliated …
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This provision authorizes disclosure of bank account information to third-party business partners for referral validation purposes, which may engage financial data protection requirements under the Gramm-Leach-Bliley Act and applicable state financial privacy statutes depending on the nature of the business relationship.
Under this clause, ADP may share an individual's contact information and bank account information with business partners for referral validation where the individual has interacted with or been referred by that partner. The policy does not specify the technical or contractual safeguards applied to bank account information shared with business partners in this context.
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