The policy discloses that Equifax shares personal information with third parties for cross-context behavioral advertising and authorizes consumers in California and certain other states to opt out of this sharing.
This analysis describes what Equifax'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 Equifax engages in data sharing practices that qualify as a sale or share under CPRA and potentially other state privacy statutes, triggering opt-out rights for residents of qualifying states and requiring a conspicuous opt-out mechanism.
Interpretive note: The policy does not specify which categories of personal data are included in behavioral advertising sharing arrangements or whether inferences derived from credit data are included, creating uncertainty about the scope of data subject to the opt-out.
Under this provision, Equifax shares personal information with third-party advertising partners for behavioral targeting purposes; consumers in California, Virginia, Colorado, Connecticut, and Texas may opt out of this sharing through Equifax's privacy portal or by using the opt-out link provided in the policy.
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"We may share your personal information with third parties for cross-context behavioral advertising purposes. California residents and residents of certain other states have the right to opt out of the sale or sharing of their personal information.— Excerpt from Equifax's Equifax Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly implicates the CPRA, which requires businesses that sell or share personal information for cross-context behavioral advertising to provide a conspicuous opt-out mechanism and to honor opt-out preference signals. Virginia's VCDPA, Colorado's CPA, Connecticut's CTDPA, and Texas's TDPSA contain analogous opt-out rights. The California Privacy Protection Agency and the California Attorney General share enforcement authority under CPRA. The FTC's authority over unfair or deceptive practices is also relevant if opt-out mechanisms are not functional or honored. 2. GOVERNANCE EXPOSURE: High. The combination of Equifax's status as a data broker and its sharing of behavioral data for advertising creates compounded exposure under both state privacy laws and FTC oversight. If Equifax's advertising data sharing incorporates inferences derived from credit or financial data, additional restrictions under CPRA's sensitive data framework may apply. 3. JURISDICTION FLAGS: California residents have the strongest statutory opt-out rights under CPRA, including the right to direct Equifax not to share data via the Global Privacy Control signal. EU and UK data subjects have stronger protections under GDPR, where sharing for behavioral advertising typically requires explicit consent rather than an opt-out model. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving data from Equifax under these sharing arrangements should confirm that data use agreements comply with CPRA's contractual requirements for third parties receiving personal information, including prohibitions on further sale without consumer consent. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that Equifax's opt-out mechanism honors Global Privacy Control signals as required by CPRA regulations, that the opt-out is accessible from the homepage and all data collection pages, and that the categories of data shared for advertising do not include sensitive personal information without explicit consumer consent.
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This provision establishes that Equifax engages in data sharing practices that qualify as a sale or share under CPRA and potentially other state privacy statutes, triggering opt-out rights for residents of qualifying states and requiring a conspicuous opt-out mechanism.
Under this provision, Equifax shares personal information with third-party advertising partners for behavioral targeting purposes; consumers in California, Virginia, Colorado, Connecticut, and Texas may opt out of this sharing through Equifax's privacy portal or by using the opt-out link provided in the policy.
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