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The policy states Harvey does not sell personal data for payment but acknowledges that sharing data with advertising partners, analytics providers, and social networks for targeted advertising purposes may qualify as a sale or sharing under the CCPA. An opt-out mechanism is available under 'Your Privacy Choices' on the Harvey website.
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 creates an operational CCPA compliance obligation requiring a functioning opt-out mechanism for targeted advertising data flows. The terms authorize disclosure of website visitor Personal Data to advertising, analytics, and social network partners, and the document acknowledges this may trigger CCPA sale or sharing definitions, which require California residents to be provided with an accessible opt-out pathway.
Under this clause, Personal Data of Harvey website visitors may be shared with advertising partners, analytics providers, and social networks in a manner the agreement acknowledges could constitute a CCPA sale or sharing. California residents and potentially residents of other US states with similar privacy statutes can opt out of this data sharing via the 'Your Privacy Choices' link on the Harvey website.
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"Harvey does not sell or share personal data with third parties in exchange for payment. However, to the extent permitted by applicable law we may provide Personal Data of individuals who visit our Websites or otherwise provide their Personal Data for marketing purposes to third party partners, such as advertising partners, analytics providers, and social networks, who assist us in advertising our products and services to you. This may be considered a data "sale" or "sharing" as those terms are defined under the CCPA and other applicable US privacy laws. To our knowledge, Harvey does not sell personal information of minors under 18 years of age.Excerpt from Harvey AI's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly implicates the CCPA as amended by the CPRA, which requires businesses to disclose and honor opt-out rights for data sales and sharing for cross-context behavioral advertising. Enforcement is conducted by the California Privacy Protection Agency (CPPA) and the California Attorney General. Other state privacy laws including Virginia's VCDPA, Colorado's CPA, and Connecticut's CTDPA contain similar targeted advertising opt-out requirements that may also apply depending on the user's state of residence. (2) GOVERNANCE EXPOSURE: Medium. The document's acknowledgment that data sharing with advertising partners may qualify as a CCPA sale or sharing is a compliance trigger requiring a verified opt-out mechanism. The sufficiency of the 'Your Privacy Choices' mechanism, including whether it covers all downstream advertising data flows and whether it is implemented consistently across all website entry points, warrants technical audit. (3) JURISDICTION FLAGS: California residents have enforceable opt-out rights under the CCPA. Residents of Virginia, Colorado, Connecticut, Texas, and other states with enacted privacy laws may have analogous rights. The provision's scope is limited to website visitors and individuals providing Personal Data for marketing purposes, which may not capture all data subjects whose information is shared with advertising partners. (4) CONTRACT AND VENDOR IMPLICATIONS: Contracts with advertising partners, analytics providers, and social networks should be reviewed to confirm they include appropriate CCPA service provider or contractor terms, or that data sharing agreements accurately characterize the nature of the data exchange. If advertising partners use received data for their own purposes, those arrangements may not qualify for service provider treatment under the CCPA. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the 'Your Privacy Choices' opt-out mechanism is technically functional, logs opt-out signals, and communicates those signals to all downstream advertising and analytics partners. A data flow audit should identify all third-party recipients of website visitor Personal Data to confirm the disclosure is complete and accurate. Annual review of advertising partner contracts should confirm continued alignment with CCPA requirements.
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This provision creates an operational CCPA compliance obligation requiring a functioning opt-out mechanism for targeted advertising data flows. The terms authorize disclosure of website visitor Personal Data to advertising, analytics, and social network partners, and the document acknowledges this may trigger CCPA sale or sharing definitions, which require California residents to be provided with an accessible opt-out pathway.
Under this clause, Personal Data of Harvey website visitors may be shared with advertising partners, analytics providers, and social networks in a manner the agreement acknowledges could constitute a CCPA sale or sharing. California residents and potentially residents of other US states with similar privacy statutes can opt out of this data sharing via the 'Your Privacy Choices' link on …
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