No Targeted Advertising Sale Disclosure

What it is

The policy affirmatively states that Figure AI does not sell, share, or process personal data for targeted advertising purposes and has not done so during the preceding 12 months.

Why it matters (compliance & governance perspective)

This affirmative disclosure addresses opt-out rights under CCPA and similar state privacy laws that grant consumers the right to opt out of the sale or sharing of personal data for targeted advertising. The disclosure establishes that no such opt-out mechanism is necessary given the stated absence of these practices.

Consumer impact (what this means for users)

The agreement states that personal data is not sold or shared for targeted advertising purposes, which means no opt-out action is required for this category of data use. The policy notes that Figure AI may disclose personal data to advertising partners in connection with profile and contact data, web analytics, and geolocation data, but states these disclosures do not constitute targeted advertising sales.

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: This disclosure engages CCPA, CPRA, and analogous U.S. state privacy laws requiring disclosure of whether personal data is sold or shared for targeted advertising. The affirmative non-sale statement satisfies the disclosure obligation under these frameworks and eliminates the need to provide an opt-out mechanism for targeted advertising sales. The FTC monitors the accuracy of such disclosures under its authority over deceptive practices. 2) GOVERNANCE EXPOSURE: Low. The affirmative non-sale disclosure is consistent with the policy's description of advertising partners as recipients of profile, web analytics, and geolocation data. If advertising partner disclosures constitute sales or sharing for targeted advertising under applicable law despite the stated position, there would be a compliance gap requiring evaluation. The policy's listing of advertising partners as data recipients creates a factual question for regulators as to whether these disclosures constitute sales under applicable definitions. 3) JURISDICTION FLAGS: California (CCPA/CPRA) defines sale and sharing broadly, and the California Privacy Protection Agency has enforcement authority over whether disclosures to advertising partners constitute sharing for cross-context behavioral advertising. Colorado, Connecticut, and other states define targeted advertising and sale differently, which may affect whether the stated position holds under each framework. 4) CONTRACT AND VENDOR IMPLICATIONS: Agreements with advertising partners listed as recipients of profile, web analytics, and geolocation data should be reviewed to confirm the nature of the data processing relationship and whether it meets applicable legal definitions of sale or sharing for targeted advertising. Service provider agreements should include restrictions on independent use of personal data for advertising purposes. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether disclosures of profile, web analytics, and geolocation data to advertising partners constitute sharing for cross-context behavioral advertising under CCPA/CPRA or analogous state definitions. If the factual analysis supports the non-sale position, documentation of that analysis should be maintained. Annual review of this disclosure against actual data flows is recommended.

Applicable agencies

Provision details

Other risks in this policy

• Consent-by-Use Mechanism medium
• Sensory Data Collection high
• Business Transfer Data Disclosure medium
• Data Retention Policy medium
• Do Not Track Non-Support medium
• U.S. State Privacy Rights Exercise Process low