Delta Airlines · Delta Privacy Policy · View original document ↗

Promotional Partner Data Sharing

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Visit Delta's Privacy and Security page at delta.com/us/en/legal/privacy-and-security and locate the opt-out or privacy request form. Submit your request to opt out of promotional partner data sharing.

How other platforms handle this

Lime Medium

We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...

Oura Medium

We process personal data you provide to Oura to enable third party integrations, services, features, and offerings. For example, with your permission, our Services may integrate with third-party services like Google Health Connect and Apple HealthKit, or those of our partners. Oura takes measures to...

Substack Medium

Creators: when you subscribe to a Creator's publication, we provide them the information necessary (including your name and email address) to provide you their publication(s). Please note that Creators control their own publications; accordingly, when you interact with a Creator's publication in a w...

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC oversees unfair or deceptive practices in consumer data sharing and has enforcement authority over privacy policy disclosures and third-party data transfers.
    File a complaint →
  • State AG
    State attorneys general, particularly California's, have enforcement authority over CCPA/CPRA violations related to the sharing of personal information with promotional partners.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Delta Privacy Policy
Entity
Delta Airlines
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-004500
Document ID
CA-D-00629
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8457cf035cfa0c5237d80b10b4c903590ea2ec5f3361da5dd4a6cf53812f2c41
Analysis generated
May 7, 2026 05:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Delta Airlines
Document: Delta Privacy Policy
Record ID: CA-P-004500
Captured: 2026-05-07 05:33:19 UTC
SHA-256: 8457cf035cfa0c52…
URL: https://conductatlas.com/platform/delta-airlines/delta-privacy-policy/promotional-partner-data-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Delta Airlines's Promotional Partner Data Sharing clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Delta Airlines?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Delta Airlines.