Best Buy shares your personal data with advertising and analytics companies to serve you targeted ads, and acknowledges this sharing may qualify as selling your personal information under California law.
This analysis describes what Best Buy'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
The policy discloses that data sharing with advertising partners may constitute a sale or sharing under CCPA/CPRA, which triggers opt-out rights for California residents and creates compliance obligations for Best Buy regarding the clarity and accessibility of the opt-out mechanism.
Interpretive note: The full enumeration of advertising and analytics partners and the precise scope of data categories shared with each partner was not fully available in the document portion reviewed.
The policy states Best Buy shares consumer data including browsing activity and identifiers with advertising and analytics partners, and acknowledges this may qualify as a sale under California law, meaning California residents have a statutory right to opt out of this data sharing.
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"We may share your personal information with third parties such as advertising partners, analytics providers, and other companies that help us market and improve our products and services. Some of this sharing may constitute a 'sale' or 'sharing' of personal information as defined under the California Consumer Privacy Act. We use cookies, pixel tags, and similar technologies to collect information about your online activities across our websites and third-party sites to serve you targeted advertisements.— Excerpt from Best Buy's Best Buy Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly engages CCPA/CPRA, which requires businesses that sell or share personal information to provide a clear opt-out right and a 'Do Not Sell or Share My Personal Information' link. The California Privacy Protection Agency and California Attorney General enforce these requirements. The provision's acknowledgment that sharing may constitute a sale is a legally significant disclosure that triggers specific statutory obligations. 2. GOVERNANCE EXPOSURE: High. The explicit acknowledgment that advertising data flows may constitute a sale or sharing under CCPA/CPRA creates material compliance obligations. Failure to maintain an accessible and functional opt-out mechanism, or to honor opt-out requests within the 15-business-day window required by CCPA, could expose Best Buy to regulatory action. This provision also requires evaluation under analogous state laws in Virginia, Colorado, and Connecticut, which have their own opt-out frameworks for targeted advertising. 3. JURISDICTION FLAGS: California creates the most immediate statutory exposure given the explicit CCPA/CPRA acknowledgment. Virginia's CDPA, Colorado's CPA, and Connecticut's CTDPA require opt-out rights for targeted advertising that may apply to Best Buy's practices. The use of cross-site tracking technologies may also engage state wiretapping or electronic communications statutes in certain jurisdictions. 4. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with advertising and analytics partners should be reviewed to confirm they include the contractual restrictions required for service provider or contractor status under CCPA/CPRA. Partners that receive data classified as sold or shared must be identified in the policy; gaps in vendor disclosure may create compliance exposure. 5. COMPLIANCE CONSIDERATIONS: The opt-out mechanism for sale and sharing of personal information should be audited for accessibility, functionality, and response time compliance with CCPA's 15-business-day requirement. The policy should be reviewed to confirm that all advertising and analytics partners receiving data are appropriately classified as either service providers or third parties, with corresponding contractual protections in place.
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The policy discloses that data sharing with advertising partners may constitute a sale or sharing under CCPA/CPRA, which triggers opt-out rights for California residents and creates compliance obligations for Best Buy regarding the clarity and accessibility of the opt-out mechanism.
The policy states Best Buy shares consumer data including browsing activity and identifiers with advertising and analytics partners, and acknowledges this may qualify as a sale under California law, meaning California residents have a statutory right to opt out of this data sharing.
ConductAtlas has identified this type of provision across 13 platforms. See the full comparison.
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