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The notice states that DocuSign does not knowingly sell personal information of minors under 16 without legally required affirmative authorization, and that the company recognizes browser-based opt-out preference signals in accordance with applicable law.
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 addresses CCPA-specific obligations regarding minor data and browser-based opt-out signals, including Global Privacy Control recognition. The statement that DocuSign's services are not designed for or marketed to minors under 18 is separately established in the Children's Privacy section.
The agreement states that personal information of users under 16 will not be sold without affirmative authorization, and that browser-based opt-out signals such as Global Privacy Control will be recognized where required by applicable law.
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"Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization. Please note that if you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.Excerpt from DocuSign's Privacy Statement
1. REGULATORY LANDSCAPE: This provision engages CCPA Section 1798.120 regarding the sale of personal information of minors, which requires opt-in consent for minors under 16 and verified parental consent for minors under 13. The recognition of browser-based opt-out signals engages California Attorney General guidance on Global Privacy Control compliance under CCPA. Other state privacy laws may impose similar or additional requirements. 2. GOVERNANCE EXPOSURE: Low. DocuSign's services are stated to not be designed for or marketed to minors, reducing the operational likelihood of minor data collection. The browser-based signal recognition provision reflects compliance with California regulatory guidance. 3. JURISDICTION FLAGS: California is the primary jurisdiction engaged by this provision. Other states including Colorado and Connecticut have adopted opt-out signal recognition requirements. The provision applies in accordance with applicable law, meaning its operational scope may vary by jurisdiction. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers deploying DocuSign in contexts where minor users could potentially access services should evaluate whether additional contractual protections are required given DocuSign's stated limitation on minor data sales. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that DocuSign's implementation of browser-based opt-out signal recognition functions as described across marketing website contexts, and that the opt-out mechanism in the website footer satisfies applicable state regulatory requirements.
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This provision addresses CCPA-specific obligations regarding minor data and browser-based opt-out signals, including Global Privacy Control recognition. The statement that DocuSign's services are not designed for or marketed to minors under 18 is separately established in the Children's Privacy section.
The agreement states that personal information of users under 16 will not be sold without affirmative authorization, and that browser-based opt-out signals such as Global Privacy Control will be recognized where required by applicable law.
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