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DraftKings authorizes a named list of advertising vendors including Facebook, TikTok, LiveRamp, The Trade Desk, Reddit, Snapchat, FantasyPros, TruSignal, and Twitter to collect user data including IP address, email address, browser identifiers, and commercial purchase history across DraftKings and third-party websites and applications via cookies, pixel tags, and related technologies.
This analysis describes what DraftKings'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 authorizes cross-site data collection by a named list of advertising and data broker intermediaries, including LiveRamp, which is a data onboarding and identity resolution vendor. The collection of email addresses as unique personal identifiers for cross-site tracking purposes may constitute a sale or sharing of personal information under CCPA, requiring an opt-out mechanism. The notice directs users to http://www.aboutads.info/choices and https://www.networkadvertising.org/ for opt-out options.
Under this provision, named advertising vendors may collect email addresses, IP addresses, browser identifiers, and purchase history across DraftKings and third-party platforms for interest-based advertising purposes. The agreement directs users seeking to limit this collection to opt-out resources at aboutads.info/choices and networkadvertising.org, and California residents may submit opt-out of sale or sharing requests as described in Section 12 of the notice.
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"In connection with the delivery of advertising, certain vendors, including, but not limited to, Facebook, FantasyPros, LiveRamp, Reddit, Snapchat, TikTok, The Trade Desk, TruSignal, and Twitter, may collect information about you and your visits to the Website and Applications and other websites and applications. That information may include your IP address, internet service provider, unique personal identifiers (e.g., email address), the browser you use to visit the Website and Applications and other websites and applications, and certain commercial information such as records of products or services purchased, obtained, or considered. They may do this by using cookies, pixel tags, or other technologies.Excerpt from DraftKings's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA, under which sharing personal information including email addresses and browsing data with advertising vendors for cross-context behavioral advertising may constitute a sale or sharing of personal information requiring an opt-out mechanism. The FTC Act applies to data broker and advertising network practices. State consumer privacy laws in Colorado, Connecticut, Virginia, Texas, and other states with opt-out rights for targeted advertising are also engaged. The inclusion of LiveRamp, a data onboarding and identity resolution intermediary, raises data broker disclosure considerations under applicable state law. 2) GOVERNANCE EXPOSURE: High. The collection of email addresses as unique cross-site identifiers by named vendors including LiveRamp and The Trade Desk constitutes data sharing that may trigger CCPA sale or sharing opt-out obligations. The notice acknowledges this by directing California residents to Section 12 for opt-out procedures. However, the adequacy of the opt-out mechanism and Global Privacy Control (GPC) signal recognition for non-California users requires verification against applicable state law obligations. 3) JURISDICTION FLAGS: California creates the highest exposure given CPRA's opt-out right for sharing of personal information for cross-context behavioral advertising. Colorado, Connecticut, and Virginia residents have analogous opt-out rights under their respective state statutes. Texas and Oregon also impose targeted advertising opt-out requirements. The notice's referral to external industry opt-out tools (DAA, NAI) rather than an in-product opt-out control for all states may require evaluation against jurisdiction-specific implementation requirements. 4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with each named advertising vendor should be reviewed to confirm CCPA-compliant data use restrictions and prohibition on further sale of personal information received from DraftKings. LiveRamp's role as an identity resolution intermediary creates particular data mapping complexity, as user email addresses may be matched to broader identity graphs beyond DraftKings' direct control. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that DraftKings honors Global Privacy Control signals for California and Colorado users as required under applicable state law. The opt-out mechanism described in the notice should be audited for functionality and accessibility. Data processing agreements with all named advertising vendors should be confirmed to include contractual prohibitions on downstream sale or sharing of personal information received from DraftKings.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision authorizes cross-site data collection by a named list of advertising and data broker intermediaries, including LiveRamp, which is a data onboarding and identity resolution vendor. The collection of email addresses as unique personal identifiers for cross-site tracking purposes may constitute a sale or sharing of personal information under CCPA, requiring an opt-out mechanism. The notice directs users to …
Under this provision, named advertising vendors may collect email addresses, IP addresses, browser identifiers, and purchase history across DraftKings and third-party platforms for interest-based advertising purposes. The agreement directs users seeking to limit this collection to opt-out resources at aboutads.info/choices and networkadvertising.org, and California residents may submit opt-out of sale or sharing requests as described in Section 12 of the …
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