Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
In the event of a business reorganization including a sale, merger, or asset transfer, Harvey may disclose Personal Data to counterparties during due diligence and transfer it to a successor entity. The terms state Harvey will notify users if it intends to transfer their information.
This analysis describes what Harvey 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
This provision authorizes disclosure of Personal Data to third-party counterparties during due diligence processes before any transaction is completed. The notification commitment is stated but does not specify a timeline, method, or minimum notice period, which may affect practical enforceability of the notification right.
Interpretive note: The notification commitment does not specify a timeline, method, or minimum advance notice period, creating ambiguity about the practical scope of the notification obligation.
Under this clause, Personal Data may be shared with transaction counterparties and advisors during due diligence for a potential sale, merger, or restructuring. The agreement states that Harvey will notify users if it intends to transfer their information, though the terms do not specify the timing or method of that notification.
Cross-platform context
See how other platforms handle Business Reorganization Data Disclosure and similar clauses.
Compare across platforms →Monitoring
Harvey AI has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"In some cases, we may choose to reorganize our business (such as via a sale, merger, liquidation, receivership, or transfer of all or substantially all of Harvey's assets). Your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction. If Harvey intends to transfer information about you, we will notify you.Excerpt from Harvey AI's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision may require evaluation under GDPR Article 6 regarding the sufficiency of legitimate interests as a legal basis for pre-transaction due diligence disclosures, and under GDPR Article 13 and 14 regarding notification obligations when data is shared with new controllers. The CCPA's disclosure requirements regarding data sharing with third parties in business transfer contexts may also apply. The FTC has addressed data transfer in business acquisition contexts in prior enforcement actions involving successor liability for privacy commitments. (2) GOVERNANCE EXPOSURE: Medium. The authorization to disclose Personal Data to counterparties during due diligence prior to transaction completion is standard in commercial agreements but may create tension with GDPR data minimization and purpose limitation principles if disclosures are not limited to necessary categories of data. The absence of a specified notification timeline for post-transaction transfers reduces the practical value of the notification commitment. (3) JURISDICTION FLAGS: EU and UK data subjects may have rights to object to processing for business reorganization purposes under GDPR Article 21, depending on the legal basis relied upon. The policy identifies legitimate interests as the basis for this processing. California residents may have rights under the CCPA to know about transfers to successor entities. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess whether their Customer Agreements with Harvey include specific provisions governing data handling in the event of a Harvey business reorganization, including requirements that successor entities honor existing data processing terms. The absence of a specified due diligence data room access protocol in this policy may warrant inquiry during procurement. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that any due diligence disclosure of customer Personal Data is limited to data categories necessary for the transaction and is governed by appropriate confidentiality obligations with counterparties. Organizations subject to GDPR should assess whether the notification commitment satisfies Article 13 and 14 transparency requirements in the context of a controller change.
Full institutional analysis
Regulatory citations, enforcement risk, and due diligence action items.
Monitor: same-day alerts on the platforms you choose. Analyst: full institutional analysis.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision authorizes disclosure of Personal Data to third-party counterparties during due diligence processes before any transaction is completed. The notification commitment is stated but does not specify a timeline, method, or minimum notice period, which may affect practical enforceability of the notification right.
Under this clause, Personal Data may be shared with transaction counterparties and advisors during due diligence for a potential sale, merger, or restructuring. The agreement states that Harvey will notify users if it intends to transfer their information, though the terms do not specify the timing or method of that notification.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Harvey AI.