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The notice states that personal information may be disclosed to third parties during due diligence or upon completion of corporate transactions including mergers, sales, and bankruptcy proceedings, and that DocuSign will notify users of changes to data control and available choices if a transaction occurs.
This analysis describes what DocuSign'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 reserves DocuSign's right to transfer user personal information as part of business asset transactions, including in bankruptcy contexts. The commitment to notify users of control changes and available choices is stated but the notice does not specify the timing, method, or content of such notification.
Under this provision, personal information including identifiers, transaction data, and account data may be disclosed to acquiring or successor entities as part of corporate transactions. The agreement states that DocuSign will notify users of control changes and available choices if such a transaction occurs.
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"Your personal information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.Excerpt from DocuSign's Privacy Statement
1. REGULATORY LANDSCAPE: This provision engages FTC guidance on data transfers in corporate transactions, including the FTC's historical enforcement actions regarding privacy policy representations at the time of data collection. GDPR Article 13 and 14 notice obligations may require that data subjects be informed of new controller identity following a corporate transaction. CCPA disclosure obligations may be triggered if the acquiring entity intends to use personal information in materially different ways. 2. GOVERNANCE EXPOSURE: Medium. The provision is standard in commercial terms but the lack of specificity about notification timing, method, or user opt-out rights in the context of a transaction creates potential exposure if a transaction occurs and notification is inadequate under applicable law. 3. JURISDICTION FLAGS: EU/EEA users may have rights to be informed of new controller identity under GDPR following a corporate transaction. California residents may have CCPA rights if the acquiring entity applies the personal information to materially different purposes. Bankruptcy contexts may involve court-supervised data asset transfers with additional regulatory review. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose data is processed by DocuSign should evaluate their data processing agreements to determine whether adequate protections exist in the event of a DocuSign corporate transaction, including data processing agreement assignment provisions and successor entity obligations. 5. COMPLIANCE CONSIDERATIONS: Legal teams should monitor DocuSign corporate transaction announcements and evaluate whether notification and choice provisions described in this clause are fulfilled in accordance with applicable law in the event of a transaction. Internal vendor risk management programs should flag this provision for periodic review.
This provision reserves DocuSign's right to transfer user personal information as part of business asset transactions, including in bankruptcy contexts. The commitment to notify users of control changes and available choices is stated but the notice does not specify the timing, method, or content of such notification.
Under this provision, personal information including identifiers, transaction data, and account data may be disclosed to acquiring or successor entities as part of corporate transactions. The agreement states that DocuSign will notify users of control changes and available choices if such a transaction occurs.
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