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The notice authorizes third-party advertising and marketing partners to use cookies and similar technologies on DocuSign marketing websites to deliver targeted advertising, while stating that such cookies are not deployed within eSignature, CLM, and Identity products and that customer data is not disclosed to advertising and marketing partners.
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 establishes that advertising partner data sharing is limited to marketing website contexts and is not applied within DocuSign's core product infrastructure. Enterprise customers should note that this carve-out applies specifically to customer data and core products, while marketing website visitors remain subject to third-party advertising cookie deployment.
The agreement authorizes disclosure of identifiers and internet activity data to advertising and marketing partners on DocuSign marketing websites through cookies and similar technologies. Under this clause, users can opt out of such data sharing for targeted advertising purposes by clicking the 'Your Privacy Choices' link in the website footer.
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"We may allow third-party advertising and marketing technologies and parties that support our advertising and marketing efforts (e.g., ad networks, ad measurement services, advertising analytics providers, remarketing providers, etc.) on our marketing websites that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the marketing websites and other websites you visit and applications you use. Note that we do not deploy third-party advertising cookies in our products used by customers, such as eSignature, Contact Lifecycle, and Identify or disclose customer data to advertising and marketing partners.Excerpt from DocuSign's Privacy Statement
1. REGULATORY LANDSCAPE: This provision engages CCPA opt-out rights for sales and sharing of personal information for targeted advertising, as well as GDPR and ePrivacy Directive requirements for cookie consent on marketing websites. The FTC Act is implicated through representations about the scope of advertising partner disclosures. State privacy laws in Virginia, Colorado, Connecticut, and Texas may also engage opt-out obligations for targeted advertising processing. 2. GOVERNANCE EXPOSURE: Medium. The provision authorizes sharing of identifiers and internet activity data with ad networks, measurement services, analytics providers, and remarketing providers on marketing websites. While the notice carves out core products, the marketing website data sharing may constitute a 'sale' or 'sharing' under CCPA and equivalent state laws, requiring compliant opt-out mechanisms. 3. JURISDICTION FLAGS: California residents have a statutory right to opt out of the sale and sharing of personal information for targeted advertising under CCPA. EU/EEA visitors to marketing websites require cookie consent under the ePrivacy Directive prior to non-essential cookie deployment. Illinois, Virginia, Colorado, and other state privacy law jurisdictions may impose additional opt-out or consent obligations. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers using DocuSign as a service provider under CCPA should confirm that the carve-out for customer data and core products is reflected in their data processing agreements, and that DocuSign's advertising partner disclosures do not implicate customer data shared through eSignature or related products. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the 'Your Privacy Choices' footer link functions as a compliant opt-out mechanism under applicable state privacy laws, and evaluate whether the Cookie Preference Center satisfies GDPR consent requirements for EU/EEA marketing website visitors. Internal data mapping should distinguish between marketing website data flows and core product data flows as described in this provision.
This provision establishes that advertising partner data sharing is limited to marketing website contexts and is not applied within DocuSign's core product infrastructure. Enterprise customers should note that this carve-out applies specifically to customer data and core products, while marketing website visitors remain subject to third-party advertising cookie deployment.
The agreement authorizes disclosure of identifiers and internet activity data to advertising and marketing partners on DocuSign marketing websites through cookies and similar technologies. Under this clause, users can opt out of such data sharing for targeted advertising purposes by clicking the 'Your Privacy Choices' link in the website footer.
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