The policy states that Equifax and its service providers use cookies, pixels, web beacons, and log files to collect device identifiers, IP addresses, browser type, operating system, browsing history, and behavioral data from users of its websites and mobile applications for analytics and advertising purposes.
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 behavioral and device data is collected through automated tracking technologies not only by Equifax but also by third-party service providers and advertising partners, creating data flows that may qualify as sales or shares under CPRA and that engage GDPR's consent requirements for non-essential cookies.
Interpretive note: The policy does not enumerate all third-party tracking vendors or specify whether the Ketch consent management platform visible in the page source constitutes full GDPR and CPRA-compliant consent management for all non-essential tracking technologies.
Under this provision, Equifax and third-party partners collect IP addresses, device identifiers, browsing activity, and behavioral data through cookies and tracking pixels on Equifax's digital properties; consumers may manage cookie preferences through Equifax's cookie consent tool and may opt out of behavioral advertising data sharing through the privacy portal.
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"We and our service providers and partners use cookies, web beacons, pixel tags, log files, and other tracking technologies to collect information about your use of our websites and mobile applications, including your IP address, browser type, device type, operating system, referring URL, pages viewed, links clicked, and the date and time of your visit.— Excerpt from Equifax's Equifax Privacy Policy
1. REGULATORY LANDSCAPE: Tracking technology data collection engages CPRA's definition of personal information and sharing for cross-context behavioral advertising, GDPR's requirements for informed consent to non-essential cookies under ePrivacy Directive principles, and the FTC's guidance on online behavioral advertising. The California Privacy Protection Agency and State AGs are relevant enforcement authorities for U.S. consumers; EU data protection authorities are relevant for EU residents. 2. GOVERNANCE EXPOSURE: Medium. The involvement of third-party advertising and analytics partners in data collection through Equifax's digital properties creates joint data controller considerations under GDPR and may implicate CPRA's opt-out signal requirements if these partners receive data that qualifies as a sale or share. The policy's reference to the Ketch consent management platform in the page source suggests a technical consent infrastructure is in place, but its scope and configuration are not described in the policy text. 3. JURISDICTION FLAGS: EU and UK residents are entitled to granular cookie consent controls under GDPR and ePrivacy principles. California residents are entitled to opt out of data sharing through tracking technologies for behavioral advertising under CPRA, including via the Global Privacy Control signal. Illinois BIPA may apply if any biometric data is collected through device sensors, though this is not indicated in the policy. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party analytics and advertising vendors receiving behavioral data through Equifax's tracking infrastructure should be assessed for CPRA third-party versus service provider classification, as the contractual obligations differ significantly between the two categories. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the full list of third-party tracking vendors operating on Equifax's digital properties, confirm that cookie consent management covers all non-essential tracking technologies, and verify that Global Privacy Control opt-out signals are honored as required by CPRA regulations.
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This provision establishes that behavioral and device data is collected through automated tracking technologies not only by Equifax but also by third-party service providers and advertising partners, creating data flows that may qualify as sales or shares under CPRA and that engage GDPR's consent requirements for non-essential cookies.
Under this provision, Equifax and third-party partners collect IP addresses, device identifiers, browsing activity, and behavioral data through cookies and tracking pixels on Equifax's digital properties; consumers may manage cookie preferences through Equifax's cookie consent tool and may opt out of behavioral advertising data sharing through the privacy portal.
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