Fireworks AI · Fireworks AI Privacy Policy · View original document ↗

Third-Party Data Broker Acquisition for Marketing

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Fireworks AI may buy your name and mailing address from data brokers or other third parties and combine that purchased information with data it already holds about you to send you marketing mail.

This analysis describes what Fireworks AI'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause establishes the operational basis for Fireworks AI's direct mail marketing program, specifying that the company sources contact information from external data brokers rather than solely from direct user interactions. The provision clarifies that combined data sets—whether from third-party brokers or direct collection—are governed under the company's Privacy Notice framework.

Consumer impact (what this means for users)

Your personal data may be acquired from data brokers and combined with your account data, which could result in receiving unsolicited direct mail and in Fireworks holding a richer profile of you than you explicitly consented to. California residents have the right to opt out of the sale or sharing of their personal information by contacting privacy@fireworks.ai.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Send an email to privacy@fireworks.ai requesting that Fireworks cease using data acquired from third-party brokers in connection with your profile, and request deletion of any such externally sourced personal data.

Cross-platform context

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Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
Data Providers. To provide our direct mail marketing services, we may purchase or receive personal data, such as name and mailing addresses, from data providers and third parties. We use this information to send Fireworks mailings with information on new products and services offered by Fireworks or our clients. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined information.

— Excerpt from Fireworks AI's Fireworks AI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision implicates CCPA and CPRA, which require disclosure of data broker sourcing and provide California residents with opt-out rights for sale or sharing of personal information. GDPR Article 14 requires notice to individuals whose data is obtained from third parties, including the source and categories of data, which this policy partially addresses but may not satisfy in full depending on implementation. The FTC Act applies to potentially deceptive or unfair acquisition and combination practices. GOVERNANCE EXPOSURE: High. The purchase and combination of externally sourced personal data with internally held account data creates compounding data lineage and consent chain obligations. The statement that this notice governs the combined information may not be sufficient to satisfy Article 14 individual notification requirements under GDPR, which have specific timing and delivery obligations. JURISDICTION FLAGS: California residents under CPRA have the right to know about data broker sourcing and to opt out. EU and UK users have Article 14 rights to notification when data is not collected directly from them. Illinois, Virginia, Colorado, and other states with comprehensive privacy laws may impose similar obligations. Heightened exposure exists for EU and California-based users. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose employee data may be included in purchased data broker lists should assess whether their own employee privacy notices and consent mechanisms account for this downstream processing. Data broker vendor agreements used by Fireworks should be assessed for adequacy under applicable data protection law. COMPLIANCE CONSIDERATIONS: Compliance teams should map the data broker acquisition pipeline, confirm whether Article 14 notices are being delivered to EU users whose data is sourced externally, and verify that CCPA-compliant opt-out mechanisms for data broker-sourced data are accessible and functional. The policy should be reviewed to confirm that marketing use of broker-sourced data is covered by an appropriate legal basis beyond the current notice-only approach.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over data broker acquisition and combination practices under Section 5 of the FTC Act and has issued guidance on consumer privacy expectations around data broker use.
    File a complaint →
  • State AG
    State attorneys general in California, Virginia, Colorado, and other states with comprehensive privacy laws have enforcement authority over data broker acquisition and combination practices that may violate state consumer privacy statutes.
    File a complaint →

Provision details

Document information
Document
Fireworks AI Privacy Policy
Entity
Fireworks AI
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-008073
Document ID
CA-D-00484
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b61873a71f0e16f69976b2d7aec567adda88338863f5a0e609f0ede9605388a8
Analysis generated
May 10, 2026 02:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Fireworks AI
Document: Fireworks AI Privacy Policy
Record ID: CA-P-008073
Captured: 2026-05-10 02:12:33 UTC
SHA-256: b61873a71f0e16f6…
URL: https://conductatlas.com/platform/fireworks-ai/fireworks-ai-privacy-policy/third-party-data-broker-acquisition-for-marketing/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Fireworks AI's Third-Party Data Broker Acquisition for Marketing clause do?

This clause establishes the operational basis for Fireworks AI's direct mail marketing program, specifying that the company sources contact information from external data brokers rather than solely from direct user interactions. The provision clarifies that combined data sets—whether from third-party brokers or direct collection—are governed under the company's Privacy Notice framework.

How does this clause affect you?

Your personal data may be acquired from data brokers and combined with your account data, which could result in receiving unsolicited direct mail and in Fireworks holding a richer profile of you than you explicitly consented to. California residents have the right to opt out of the sale or sharing of their personal information by contacting privacy@fireworks.ai.

Is ConductAtlas affiliated with Fireworks AI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Fireworks AI.