Third-Party Service Provider and Partner Data Sharing

What it is

Garmin shares your personal data with outside companies that help run its services and with business partners including retailers and distributors.

Why it matters (compliance & governance perspective)

Sharing personal data including health and location data with third-party service providers and business partners expands the number of entities who hold your information and introduces additional risk of secondary use, breach, or onward transfer.

Consumer impact (what this means for users)

Your health, location, and usage data may be accessed by multiple third-party companies providing services to Garmin or partnering with Garmin commercially; the policy limits service providers to using data only for Garmin-directed purposes, but business partner sharing carries fewer stated restrictions.

What you can do

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Under GDPR, sharing personal data with third parties requires either a lawful basis such as contract necessity or legitimate interest, and service providers acting as data processors must operate under Article 28-compliant data processing agreements. Sharing with business partners who use data for their own purposes may constitute separate controller relationships requiring independent legal bases. Under CCPA and CPRA, sharing personal information with third parties for cross-context behavioral advertising constitutes 'sharing' triggering opt-out rights. GOVERNANCE EXPOSURE: Medium to High. The distinction the policy draws between service providers (restricted use) and business partners (less clearly restricted) creates ambiguity about the scope of permissible data use by the latter category. Compliance teams should map which data categories flow to which partner types and assess whether the current disclosures are sufficiently specific to satisfy GDPR transparency requirements and CPRA categories of third parties. JURISDICTION FLAGS: California residents can opt out of sharing of personal information with third parties for cross-context behavioral advertising. EU/EEA users have rights to object to data sharing based on legitimate interests. The adequacy of onward transfer protections for data shared with international partners will vary by destination country. CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should maintain a current inventory of all third-party service providers and partners receiving personal data and ensure data processing agreements are in place and current. Agreements with retail and distribution partners who receive personal data should be reviewed to confirm they include appropriate use limitations and data security requirements. COMPLIANCE CONSIDERATIONS: The policy should be reviewed to determine whether business partner data sharing is disclosed with sufficient specificity to meet GDPR and CPRA transparency requirements. Any sharing of special category health data with third parties should be subject to explicit consent and documented processor agreements. Opt-out mechanisms for CPRA-covered sharing should be verified as technically implemented.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Health and Sensitive Data Collection high
• Precise GPS Location Data Collection high
• Garmin Connect Public Activity Visibility medium
• California CCPA and CPRA Rights medium
• GDPR Data Subject Rights for EU/EEA Users medium
• International Data Transfers via Standard Contractual Clauses medium

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