The policy authorizes sharing of identifiers, device information, browsing activity, and service interaction data with advertising partners, analytics providers, and social media platforms for targeted advertising and marketing measurement purposes.
This analysis describes what Hims & Hers'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 establishes the scope of third-party data sharing for advertising purposes and, in conjunction with the pixel disclosure, triggers California opt-out rights. The sharing of service interaction data with advertising platforms on a health-focused service creates additional sensitivity given the nature of the underlying interactions.
This provision establishes that identifiers, device information, and behavioral data about platform interactions may be shared with advertising and analytics partners and social media platforms. California residents may opt out of this sharing as a sale or sharing of personal information under CCPA.
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"We may share your personal information with third-party advertising partners, analytics providers, and social media platforms to deliver targeted advertising, measure the effectiveness of our marketing campaigns, and improve our Services. This sharing may include identifiers, device information, browsing activity, and information about your interactions with our Services.— Excerpt from Hims & Hers's Hims & Hers Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages CCPA/CPRA's sale and sharing definitions, the FTC Act's prohibition on unfair or deceptive data practices, and potentially state consumer health data statutes where health-related interaction data is shared with advertising partners. Social media platform data sharing may engage additional platform-specific policies. 2) GOVERNANCE EXPOSURE: High. Sharing health platform interaction data with advertising and social media partners creates sensitivity-based exposure. If shared data can be used by recipients to infer health conditions or treatment-seeking behavior, additional restrictions under CPRA sensitive data provisions or state health data laws may apply. 3) JURISDICTION FLAGS: California CPRA is the primary framework. Washington My Health MY Data Act may apply where shared data reveals health-seeking behavior. Other state consumer privacy laws with opt-out rights for targeted advertising create overlapping obligations. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving personal information must be classified as either service providers (with contractual use restrictions) or third parties (triggering sale or sharing opt-out obligations). Contracts should be reviewed to confirm appropriate classification and downstream use restrictions. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should inventory all active advertising and analytics integrations, classify each recipient as a service provider or third party, confirm opt-out mechanisms cover all data flows, and assess whether health-adjacent interaction data requires additional consent or restriction before sharing.
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This provision establishes the scope of third-party data sharing for advertising purposes and, in conjunction with the pixel disclosure, triggers California opt-out rights. The sharing of service interaction data with advertising platforms on a health-focused service creates additional sensitivity given the nature of the underlying interactions.
This provision establishes that identifiers, device information, and behavioral data about platform interactions may be shared with advertising and analytics partners and social media platforms. California residents may opt out of this sharing as a sale or sharing of personal information under CCPA.
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