Bank of America shares your financial data with partner financial companies for joint marketing programs, and you cannot opt out of this category of sharing.
This analysis describes what Bank of America'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 means your data may flow to financial companies outside Bank of America's corporate family for co-branded or partner marketing without any opt-out right available to you.
Personal financial information you provide to Bank of America may be shared with unspecified financial company partners for joint marketing campaigns, and the notice states this sharing cannot be limited by consumers.
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Baseten...shall provide reasonable assistance to Customer, at Customer's cost, with any data protection impact assessments and prior consultations with Supervisory Authorities...
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"Reasons we can share your personal information: For joint marketing with other financial companies. Does Bank of America share? Yes. Can you limit this sharing? No.— Excerpt from Bank of America's Bank of America Privacy Notice
REGULATORY LANDSCAPE: Joint marketing sharing is permitted under GLBA's Regulation P joint marketing exception, which requires that the financial institution enter into a contractual agreement with the joint marketer restricting the use of shared information to the joint marketing purpose. The CFPB enforces compliance with this exception. The notice does not identify specific joint marketing partners, which is consistent with GLBA's disclosure standards but limits consumer transparency. GOVERNANCE EXPOSURE: Medium. The joint marketing exception is widely used in financial services and is GLBA-compliant as structured, but regulators have scrutinized whether joint marketing agreements actually restrict partner data use to the stated purpose. The absence of named partners in the notice is standard but creates accountability gaps. JURISDICTION FLAGS: California's CFIPA may impose restrictions on joint marketing data sharing that exceed GLBA's requirements, and California compliance teams should evaluate whether separate California-specific notice or consent is required for joint marketing partners. CONTRACT AND VENDOR IMPLICATIONS: Joint marketing partner contracts must include provisions restricting use of shared consumer data to the disclosed marketing purpose, consistent with GLBA requirements. Procurement and legal teams should audit these agreements to confirm restrictions are current and enforceable. COMPLIANCE CONSIDERATIONS: Compliance teams should maintain a current list of joint marketing partners, audit partner data use against contractual restrictions, and confirm that no partner is using shared consumer data for purposes beyond the joint marketing program. If the partner list changes materially, the privacy notice may need to be updated.
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This means your data may flow to financial companies outside Bank of America's corporate family for co-branded or partner marketing without any opt-out right available to you.
Personal financial information you provide to Bank of America may be shared with unspecified financial company partners for joint marketing campaigns, and the notice states this sharing cannot be limited by consumers.
ConductAtlas has identified this type of provision across 285 platforms. See the full comparison.
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