Delta gives your personal information to marketing partners, such as credit card companies with co-branded Delta cards, so those partners can send you promotional offers.
This analysis describes what Delta Airlines'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
Your personal data is not just used by Delta internally; it flows to third-party marketing partners, which broadens the number of companies that have access to your travel and contact information.
Interpretive note: Whether this sharing constitutes a regulated 'sale' or 'sharing' under CCPA/CPRA depends on the specific contractual arrangements with promotional partners and whether consideration is exchanged, which is not fully detailed in the policy text.
This provision means that your name, contact details, and potentially travel and loyalty data may be shared with third-party promotional partners for their own marketing purposes, not just Delta's operational needs. Under CCPA, this type of sharing may qualify as a 'sale' or 'sharing' of personal information, giving California residents the right to opt out.
How other platforms handle this
Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.
We may share your personal information with third parties in the following circumstances: with service providers who perform services on our behalf; with business partners with whom we jointly offer products or services; in connection with, or during negotiations of, any merger, sale of company asse...
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
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"Delta shares information about you with promotional partners so they may send you special offers and information about their products and services. Promotional partners include companies with whom Delta has marketing relationships, such as companies that offer Delta-branded credit cards and other co-branded products.— Excerpt from Delta Airlines's Delta Privacy Policy
REGULATORY LANDSCAPE: This provision engages the California Consumer Privacy Act and California Privacy Rights Act, which broadly define 'sharing' personal information for cross-context behavioral advertising and may classify this promotional partner disclosure as a regulated activity requiring opt-out mechanisms. The FTC Act is also engaged through the unfair or deceptive practices framework if opt-out mechanisms are inadequate or disclosures are misleading. The relevant enforcement authorities are the California Privacy Protection Agency (CPPA), California Attorney General, and the FTC. GOVERNANCE EXPOSURE: High. Sharing personal information with promotional partners for their independent marketing purposes is a high-exposure data practice under CCPA/CPRA, which requires clear disclosure of categories of data shared, categories of recipients, and a compliant opt-out mechanism. If the data sharing involves sensitive personal information categories, additional restrictions apply under CPRA. JURISDICTION FLAGS: California residents face the most direct regulatory protection through CCPA/CPRA. EU and UK users would engage GDPR lawful basis requirements for this type of third-party sharing, likely requiring either consent or legitimate interests assessment. Other U.S. states with comprehensive privacy laws (Virginia, Colorado, Connecticut, Texas) may also impose opt-out or disclosure requirements for this type of data sharing activity. CONTRACT AND VENDOR IMPLICATIONS: Each promotional partner receiving personal data from Delta should be subject to a data processing or data sharing agreement specifying permitted uses, retention limits, and security obligations. Legal teams should assess whether existing partner agreements are calibrated to current state privacy law requirements, particularly regarding the restriction of data use to disclosed marketing purposes only. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the current list of promotional partners receiving personal data, confirm that data sharing agreements are in place with appropriate contractual protections, verify that opt-out mechanisms for California and other state residents are functional and prominently disclosed, and review whether the categories of personal information shared are accurately and completely disclosed in the policy.
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Your personal data is not just used by Delta internally; it flows to third-party marketing partners, which broadens the number of companies that have access to your travel and contact information.
This provision means that your name, contact details, and potentially travel and loyalty data may be shared with third-party promotional partners for their own marketing purposes, not just Delta's operational needs. Under CCPA, this type of sharing may qualify as a 'sale' or 'sharing' of personal information, giving California residents the right to opt out.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Delta Airlines.