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The policy authorizes Chegg to sell or share contact information, transaction data, demographic information, device identifiers, and information about academic interests and preferences with advertising and analytics partners, social media platforms, and business partners for cross-contextual behavioral advertising purposes.
This analysis describes what Chegg'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 establishes that multiple categories of user data, including contact information, transaction history, demographic data, device identifiers, and academic interest profiles, are disclosed to third-party advertising ecosystems for behavioral targeting, triggering opt-out obligations under CCPA and equivalent state privacy statutes.
The updated policy expands disclosure of how personal data is collected, used, and shared across Chegg's services and regional contexts. Users in the EEA, UK, Switzerland, and the US now have access to region-specific privacy disclosures that detail additional legal rights applicable in their jurisdictions. The policy explicitly states that when users access services through an educational institution or employer, Chegg will share personal data and service usage information with that institution or employer to allow monitoring of service use. The policy also discloses that user-provided content, including audio, video, and written materials, may be used to train or fine-tune Chegg and third-party AI models. Users can review their region-specific disclosures and Busuu's supplemental privacy policy to understand additional rights and practices.
View change record →Under these terms, Chegg may sell or share contact information, transaction history, demographic data, device identifiers, and academic interest data with advertising partners and social media platforms for targeted advertising. The agreement establishes opt-out rights for California, Colorado, Connecticut, Utah, Virginia, and Nevada residents, as described in the policy's 'Your Choices and Opt Out Rights' section.
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"Third Parties to Whom the Data May Be Sold/Shared for Targeted Advertising: (1) Third Party Advertising and Analytics Partners; (2) Social Media and Other Third Party Platforms; (3) Third Party Business Partners ... We may share non-personal data with third parties for any purpose in our discretion and as permitted by law, including for advertising, research and marketing purposes.Excerpt from Chegg's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages CCPA and its opt-out of sale or sharing requirements enforced by the California Privacy Protection Agency, as well as Colorado CPA, Connecticut CTDPA, Virginia VCDPA, Utah UCPA, and Nevada SB 220 opt-out frameworks. The FTC Act is also relevant to the extent sharing arrangements involve unfair or deceptive practices. The policy's characterization of certain data as sold or shared for cross-contextual behavioral advertising aligns with CCPA's definition of sharing, requiring a functional opt-out mechanism. Where Chegg's student user base includes minors under 16, CCPA imposes opt-in rather than opt-out requirements for sale or sharing. GOVERNANCE EXPOSURE: High. The breadth of categories authorized for sale or sharing, including contact information, transaction history, demographic data, and academic interest profiles, combined with a predominantly student user base, creates significant compliance exposure. The inclusion of minors in the user base implicates CCPA's opt-in consent requirements for sale or sharing of data of users under 16, and the FTC's COPPA framework for users under 13. JURISDICTION FLAGS: California creates the highest exposure given CCPA's enforcement framework and the California Privacy Protection Agency's rulemaking authority. Colorado, Connecticut, Virginia, and Utah each have enacted privacy statutes with opt-out of targeted advertising requirements. EU/EEA users may be covered by country-specific policies referenced via the country menu, where GDPR's consent or legitimate interest bases for behavioral advertising may apply. Minors create heightened exposure under both CCPA and COPPA regardless of jurisdiction. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with each advertising partner, analytics vendor, and social media platform receiving sold or shared data should be reviewed for consistency with applicable state privacy law requirements including purpose limitation, security standards, and prohibition on onward sale without notice. The policy's authorization to share with 'Third Party Business Partners' whose products are bundled with Chegg's services may require review of joint marketing and co-branding agreements to confirm data sharing scope and consent mechanisms align. COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether a functional global privacy control or opt-out mechanism for sale and sharing is implemented across all Chegg services, confirm that minor user identification and consent workflows are operationally implemented for CCPA opt-in requirements, review data processing agreements with all advertising and analytics partners for purpose limitation and security obligations, and confirm that the categories listed as sold or shared are accurately mapped to actual vendor data flows.
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This provision establishes that multiple categories of user data, including contact information, transaction history, demographic data, device identifiers, and academic interest profiles, are disclosed to third-party advertising ecosystems for behavioral targeting, triggering opt-out obligations under CCPA and equivalent state privacy statutes.
Under these terms, Chegg may sell or share contact information, transaction history, demographic data, device identifiers, and academic interest data with advertising partners and social media platforms for targeted advertising. The agreement establishes opt-out rights for California, Colorado, Connecticut, Utah, Virginia, and Nevada residents, as described in the policy's 'Your Choices and Opt Out Rights' section.
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