The policy discloses that certain data transfers, including identifiers, digital activity information, VIN, and commercial information shared with advertising networks, dealers, and financial institutions, may qualify as 'sales' under applicable state privacy laws, and that consumers may have opt-out rights for these transfers.
This analysis describes what General Motors'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 identifies specific categories of personal information, including vehicle identification numbers and digital activity data, as potentially sold to third-party advertising and financial partners, triggering opt-out rights under CCPA, CPRA, and analogous state statutes that compliance teams must ensure are operationally satisfied.
The updated statement narrowed its definition of personal information from 'identifies, relates to, or could reasonably be linked to you' to 'describes, relates to, or could reasonably be linked to you.' This language change affects which information GM must treat as personal information under the policy. The revised de-identification section reorganizes prior language, now stating GM 'may use technical measures to remove information that could reasonably identify you or your vehicle' and requires 'the same safeguards from any third parties we share it with.' The policy clarifies that its protections apply to personal information dealers disclose to GM, but do not cover dealers' independent data practices. Cruise is no longer listed as a GM affiliate exempt from this privacy statement, though the scope of privacy protections for Cruise users depends on whether Cruise now operates under this statement or maintains separate privacy terms.
View change record →The agreement discloses that identifiers, digital activity information, VIN, and commercial information may be disclosed to advertising networks, GM dealers, and financial institutions in arrangements that may qualify as sales under state law; consumers in covered states have the right to opt out of these disclosures.
Cross-platform context
See how other platforms handle Data Disclosures Acknowledged as Potential Sales and similar clauses.
Compare across platforms →"Some of the disclosures of the Personal Information listed above may qualify as 'sales' under some state laws. Those categories may include: Identifiers, Digital Activity Information, and VIN may be disclosed to companies with which GM enters into business or marketing arrangements, such as third-party advertising networks, GM dealers, and financial institutions that GM works with to offer co-branded credit cards. Commercial information may be disclosed to GM dealers, and to financial institutions to which GM licenses personal information to offer co-branded credit cards.Excerpt from General Motors's GM Privacy Statement
(1) REGULATORY LANDSCAPE: The document's acknowledgment that certain disclosures may qualify as 'sales' directly engages CCPA and CPRA in California, which require a clear opt-out mechanism for data sales.
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This provision identifies specific categories of personal information, including vehicle identification numbers and digital activity data, as potentially sold to third-party advertising and financial partners, triggering opt-out rights under CCPA, CPRA, and analogous state statutes that compliance teams must ensure are operationally satisfied.
The agreement discloses that identifiers, digital activity information, VIN, and commercial information may be disclosed to advertising networks, GM dealers, and financial institutions in arrangements that may qualify as sales under state law; consumers in covered states have the right to opt out of these disclosures.
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