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The document states that Marqeta will honor Global Privacy Control opt-out signals but specifies three scenarios in which the association between a device and a prior opt-out signal may be lost: use of a different browser, browser reinstallation or certain upgrades, and clearing of cookies or browsing data. In those scenarios, the opt-out preference may not be applied.
This analysis describes what Marqeta'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 describes the technical scope and limitations of Marqeta's GPC signal recognition mechanism, which is the primary opt-out pathway for CCPA sale and sharing disclosed in Section 3 of the California supplemental notice. The stated limitations on signal persistence may warrant evaluation against California Privacy Protection Agency guidance on the durability and accessibility of opt-out mechanisms.
Interpretive note: Whether the stated GPC persistence limitations satisfy the California Privacy Protection Agency's frictionless opt-out standard depends on regulatory guidance and enforcement interpretation not determinable from the document alone.
Under this clause, the opt-out preference recorded via a Global Privacy Control signal is device-specific and browser-specific; clearing cookies, changing browsers, or reinstalling a browser may result in the opt-out preference no longer being recognized by Marqeta's systems, requiring the user to re-establish the signal.
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"If we receive and are able to process a signal from your device indicating your preference to opt out from sales or sharing of personal information, as defined by law, then we will apply that preference to personal information we collect from that device, provided that we may not be able to associate the signal to the same device if: you use a different web browser or other tool to interact with us, you make changes to your browser (e.g., uninstall and reinstall or certain types of upgrades) that impact our ability to associate the device with the signal your device originally sent, or you clear cookies or browsing data from your browser or device in a way that impacts our ability to associate the device with the signal your device originally sent.Excerpt from Marqeta's Privacy Policy
1. REGULATORY LANDSCAPE: This provision implicates the CCPA sale and sharing opt-out framework and California Privacy Protection Agency regulations requiring that opt-out mechanisms be frictionless. The California Privacy Protection Agency is the primary enforcement authority for GPC recognition requirements. The FTC may also have relevance to the extent that GPC non-recognition could constitute an unfair or deceptive practice. 2. GOVERNANCE EXPOSURE: Medium. The disclosure that GPC signal recognition may not persist across browser changes, reinstallations, or cookie clearing creates a documented gap between the stated opt-out availability and the practical continuity of that opt-out. Whether this gap satisfies the frictionless standard under California Privacy Protection Agency regulations is a compliance question that depends on regulatory guidance and enforcement interpretation. 3. JURISDICTION FLAGS: This provision applies specifically to California residents under the CCPA and to residents of other U.S. states where opt-out preference signal recognition is required under applicable state law. The Other U.S. States supplemental notice also references GPC signal recognition as applicable where required by state law. EU and UK residents' opt-out preferences are managed through separate cookie consent mechanisms rather than GPC. 4. CONTRACT AND VENDOR IMPLICATIONS: If advertising technology vendors or analytics partners process GPC signals independently, their signal handling practices must be assessed for consistency with Marqeta's stated opt-out commitments. Procurement teams should confirm that vendor contracts address GPC signal handling and the consequences of signal loss scenarios described in this provision. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should review California Privacy Protection Agency published guidance on GPC signal requirements to assess whether the persistence limitations described in this provision are consistent with regulatory expectations. Documentation of GPC signal handling practices, including the scenarios in which signal association may be lost, should be maintained as part of the CCPA compliance program. Periodic testing of GPC signal recognition across supported browsers is a recommended audit practice.
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This provision describes the technical scope and limitations of Marqeta's GPC signal recognition mechanism, which is the primary opt-out pathway for CCPA sale and sharing disclosed in Section 3 of the California supplemental notice. The stated limitations on signal persistence may warrant evaluation against California Privacy Protection Agency guidance on the durability and accessibility of opt-out mechanisms.
Under this clause, the opt-out preference recorded via a Global Privacy Control signal is device-specific and browser-specific; clearing cookies, changing browsers, or reinstalling a browser may result in the opt-out preference no longer being recognized by Marqeta's systems, requiring the user to re-establish the signal.
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