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The policy states that when a user signs up through a referral link, the referring user may receive information confirming the new user's subscription and subscription tier.
This analysis describes what Ideogram'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 that subscription status and tier information is shared with referring users as part of the referral program, which constitutes disclosure of commercial information about a user's account to another private individual.
The updated policy now provides explicit disclosure of which categories of personal information are collected and which parties receive each category. Previously, the policy required readers to consult other sections to identify this information. The updated table format discloses that identifiers such as name and email address, visual information including uploaded images, and geolocation data may be shared with other users, vendors, service providers, login integration partners, social media widgets, and affiliates. This change provides clearer visibility into data sharing practices without altering what data is collected or shared, but rather how that information is disclosed.
View change record →The updated policy no longer provides a single consolidated view of which specific categories of recipients receive which types of personal data. Previously, users could see in one table that identifiers, commercial information, geolocation data, images, account credentials, and precise location were shared with specific recipient categories such as vendors, service providers, other users, login partners, social media widgets, and tracking technology providers. The revised policy instead directs users to review other sections of the document to find this information. The specificity and accessibility of this disclosure has been reduced, though the underlying data-sharing practices may remain unchanged.
View change record →Under this provision, if a user signs up for Ideogram's Services through another user's referral link, the referring user will receive confirmation of the new subscription and the specific subscription tier selected. This disclosure occurs as a result of using a referral link and is described as necessary to perform the referral program contract.
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"With another user, when you sign up for our Services via a referral link or invitation, in our legitimate interests and to perform our contract with the other user. The user that referred you may receive information indicating that you have chosen to subscribe to the Services, and information about your subscription tier.Excerpt from Ideogram's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR transparency requirements and CCPA disclosure obligations regarding sharing of commercial information (subscription tier) with other individual users. The disclosure of subscription tier to a private individual is a specific type of peer-to-peer data sharing that may require evaluation under applicable data protection frameworks. 2) GOVERNANCE EXPOSURE: Low. The disclosure is limited to subscription status and tier, is described as necessary to perform the referral program contract, and is triggered by the new user's own action of using a referral link. However, the disclosure of subscription tier to another private user is operationally specific and may not be anticipated by all users signing up via referral links. 3) JURISDICTION FLAGS: EU users should be informed of this disclosure under GDPR transparency requirements. The policy's disclosure in this section is the primary transparency mechanism. 4) CONTRACT AND VENDOR IMPLICATIONS: No material vendor or B2B contract implications are identified for this provision. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the referral program disclosure is clearly communicated at the point of sign-up via referral link, so that new users are aware that their subscription tier will be disclosed to the referring user.
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This provision establishes that subscription status and tier information is shared with referring users as part of the referral program, which constitutes disclosure of commercial information about a user's account to another private individual.
Under this provision, if a user signs up for Ideogram's Services through another user's referral link, the referring user will receive confirmation of the new subscription and the specific subscription tier selected. This disclosure occurs as a result of using a referral link and is described as necessary to perform the referral program contract.
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