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The policy states that personal data may be transferred to third parties as an asset in connection with mergers, acquisitions, joint ventures, financings, asset sales, or insolvency proceedings, including during the negotiation phase of such transactions.
This analysis describes what LlamaIndex'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 prospective acquirers or creditors during deal negotiations and in insolvency proceedings, which may occur before any transaction is finalized and without individual user notification at the time of transfer.
Under this clause, personal data collected by LlamaIndex may be transferred to third-party acquirers or insolvency administrators as a business asset, including during pre-transaction due diligence, under the terms stated in the policy.
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"We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.Excerpt from LlamaIndex's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR requires that data transfers in the context of M&A transactions satisfy lawful basis and transparency requirements; transfers to entities in non-adequate third countries require additional safeguards. CCPA and CPRA apply to transfers of personal information as part of asset sales or business combinations. The FTC has taken enforcement positions on changes to privacy practices following acquisitions. 2) GOVERNANCE EXPOSURE: Medium. The authorization to disclose data during the negotiation phase of a transaction, before any definitive agreement, represents a disclosure trigger that may not always be associated with user notification. The policy does not describe what notification, if any, will be provided to users upon a completed transfer. 3) JURISDICTION FLAGS: EU and EEA users face heightened exposure where transfers occur to entities in third countries without adequate protection. California users may have rights regarding the treatment of their data in asset sale scenarios under CPRA. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess how a potential LlamaIndex acquisition or insolvency could affect data processing under their DPA or service provider agreement, including whether successor entities would be bound by the same contractual terms. 5) COMPLIANCE CONSIDERATIONS: Legal teams should monitor whether LlamaIndex provides notice of any completed business transaction and assess whether the successor entity's privacy practices are consistent with representations made to users. DPA terms should address successor entity obligations.
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This provision authorizes disclosure of personal data to prospective acquirers or creditors during deal negotiations and in insolvency proceedings, which may occur before any transaction is finalized and without individual user notification at the time of transfer.
Under this clause, personal data collected by LlamaIndex may be transferred to third-party acquirers or insolvency administrators as a business asset, including during pre-transaction due diligence, under the terms stated in the policy.
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