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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.
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"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. Analogous sale opt-out requirements exist under Virginia VCDPA, Colorado CPA, Connecticut CTDPA, Texas TDPSA, and other state statutes. The FTC Act applies to unfair or deceptive practices in data commercialization. The disclosure of VIN alongside identifiers and commercial data to financial institutions may engage Gramm-Leach-Bliley Act considerations where financial product offers are involved. (2) GOVERNANCE EXPOSURE: High. The acknowledgment that disclosures to advertising networks and financial institutions 'may' qualify as sales, without definitively confirming sale status, creates ambiguity that may be resolved differently under each state framework. Compliance teams must confirm that opt-out mechanisms satisfy each applicable state's opt-out standard, including California's 'Do Not Share My Personal Information' right under CPRA for targeted advertising. (3) JURISDICTION FLAGS: California creates the highest exposure given CPRA's specific requirements for sale and sharing opt-outs and its enforcement by the California Privacy Protection Agency. States with enacted comprehensive privacy laws that include sale opt-out rights include Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and others. The disclosure of VIN to financial institutions may create additional obligations in states with financial data privacy statutes. (4) CONTRACT AND VENDOR IMPLICATIONS: Business or marketing arrangement agreements with third-party advertising networks should specify the nature of the data transfer, the consideration exchanged, and the recipient's permitted use, to support the company's determination of whether each transfer constitutes a sale under applicable law. Co-branded credit card licensing agreements with financial institutions should be reviewed in light of the policy's acknowledgment of potential sale status. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the opt-out mechanisms provided, including the Consumer Preference System, the GPC signal response, and the privacy request form, collectively satisfy sale and sharing opt-out obligations under each applicable state law. The policy's statement that the company 'may' qualify certain disclosures as sales should be assessed to determine whether definitive sale status determinations have been made internally and whether those determinations are reflected in vendor agreements and consent records.
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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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