Data Sharing with Advertising and Analytics Partners

What it is

Chegg shares your personal data including browsing behavior and usage patterns with advertising and analytics companies, which may qualify as selling your data under California law.

Why it matters (compliance & governance perspective)

This provision establishes the operational scope of data disclosure practices and creates explicit notice that the company's data sharing activities may be subject to CCPA classification and related consumer rights mechanisms, including potential opt-out obligations depending on state law application.

Consumer impact (what this means for users)

Your behavioral and academic usage data may be shared with third-party ad networks for targeted advertising, creating commercial use of data generated in an educational context; California residents can opt out of this sharing under CCPA and CPRA.

What you can do

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages CCPA and CPRA, which define the sale and sharing of personal information broadly to include disclosure for cross-context behavioral advertising; the California Privacy Protection Agency and the California Attorney General are the primary enforcement authorities. Where the policy characterizes this sharing as potentially qualifying as a sale, CPRA opt-out obligations and sensitive personal information restrictions may apply. GDPR Article 6 requires a lawful basis for sharing personal data with advertising partners, and Recital 47 does not easily accommodate advertising as a legitimate interest override for all user categories. (2) GOVERNANCE EXPOSURE: High. The acknowledgment that data sharing with ad partners may constitute a sale under California law creates a direct CCPA and CPRA compliance obligation, including the requirement to honor opt-out requests and update vendor contracts to reflect data sharing restrictions. The broad scope of behavioral data shared, including academic usage patterns, may attract regulatory attention given the educational context. (3) JURISDICTION FLAGS: California creates the highest exposure given CCPA and CPRA opt-out requirements; EU and EEA users require a valid lawful basis under GDPR for each advertising data transfer; Illinois and other states with comprehensive privacy laws may impose similar opt-out requirements. For minors, sharing behavioral data with advertising partners may be prohibited or restricted under COPPA and state student privacy laws regardless of user consent. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with all advertising and analytics vendors must include CCPA-compliant contractual terms restricting use of personal information to the specified purpose; GDPR standard contractual clauses or alternative transfer mechanisms are required for EU data flows. Procurement teams should audit whether current vendor contracts reflect the policy's disclosures and whether opt-out signals such as Global Privacy Control are technically honored. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism is technically functional and that opt-out signals are propagated to all downstream advertising vendors; the policy's disclosure of potential data sales should be reflected in the company's CCPA required disclosures including the privacy notice at collection; data mapping should identify all advertising and analytics vendors receiving personal data and document the legal basis for each transfer.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Collection of Academic and Behavioral Usage Data high
• California Residents' Right to Opt Out of Sale or Sharing medium
• Cookie and Tracking Technology Use medium
• Children and Minors Data Handling high
• Data Retention medium
• User Rights and Data Access medium

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