The policy authorizes disclosure and transfer of personal data to actual or potential acquirers during and in connection with M&A transactions, restructurings, financing events, or bankruptcy proceedings, including during pre-transaction negotiations.
This analysis describes what AI21 Labs'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 personal data disclosure to third parties during M&A due diligence, which may occur before any transaction is completed and before users are notified of a change in data controller. The breadth of the authorization, which covers potential as well as actual transactions and includes the negotiation phase, is a standard but operationally material provision for compliance teams.
Under these terms, personal data collected by AI21 may be transferred to or disclosed with third parties in connection with potential or completed acquisitions, mergers, asset sales, or restructurings, including during pre-transaction negotiations. The policy does not specify a separate user notification procedure for such transfers beyond the general policy update notification mechanism.
Cross-platform context
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Compare across platforms →"If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events; In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.Excerpt from AI21 Labs's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision implicates GDPR requirements regarding lawful basis for data transfers to new controllers, including whether legitimate interest or contractual necessity can support pre-transaction disclosures during due diligence.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision authorizes personal data disclosure to third parties during M&A due diligence, which may occur before any transaction is completed and before users are notified of a change in data controller. The breadth of the authorization, which covers potential as well as actual transactions and includes the negotiation phase, is a standard but operationally material provision for compliance teams.
Under these terms, personal data collected by AI21 may be transferred to or disclosed with third parties in connection with potential or completed acquisitions, mergers, asset sales, or restructurings, including during pre-transaction negotiations. The policy does not specify a separate user notification procedure for such transfers beyond the general policy update notification mechanism.
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