The policy authorizes sharing of personal data with third-party vendors providing hosting, analytics, and advertising services, subject to contractual data protection obligations imposed on those vendors.
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 permits disclosure of personal data collected through ADP's website and marketing channels to advertising and analytics third parties, which is operationally relevant for CCPA opt-out rights and GDPR consent or legitimate interests assessments for website visitor data.
Interpretive note: The precise list of named advertising and analytics vendors and whether the sharing meets the CPRA definition of 'sharing for cross-context behavioral advertising' requires review of the California supplement and the current sub-processor or vendor list, which are not fully reproduced in the document text provided.
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, personal data collected from website visitors and business contacts may be shared with advertising and analytics vendors; the policy's technical infrastructure as observed includes third-party tracking scripts from Google, LinkedIn, Facebook, Twitter, Reddit, and other advertising platforms, which may constitute data sharing or selling under applicable state privacy laws.
How other platforms handle this
We share Personal Data with vendors, service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service.
We disclose information about you to our vendors (including our affiliates) that perform services on our behalf.
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"We may share your personal information with third-party service providers that perform services on our behalf, such as website hosting, data analysis, advertising, and other services.Excerpt from ADP's Privacy Statement
1) REGULATORY LANDSCAPE: This provision engages CCPA and CPRA (California Consumer Privacy Act and California Privacy Rights Act), which regulate the sale and sharing of personal data with third parties for cross-context behavioral advertising.
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This provision permits disclosure of personal data collected through ADP's website and marketing channels to advertising and analytics third parties, which is operationally relevant for CCPA opt-out rights and GDPR consent or legitimate interests assessments for website visitor data.
Under this clause, personal data collected from website visitors and business contacts may be shared with advertising and analytics vendors; the policy's technical infrastructure as observed includes third-party tracking scripts from Google, LinkedIn, Facebook, Twitter, Reddit, and other advertising platforms, which may constitute data sharing or selling under applicable state privacy laws.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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