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The policy discloses that targeting cookies set by McDonald's or its advertising partners may be used to build interest profiles and deliver advertising on third-party sites, and that these cookies may interact with other third-party cookies in the user's browser, with tracking occurring over time and across multiple websites and devices.
This analysis describes what McDonald's'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 cross-site and cross-device behavioral tracking for advertising purposes by McDonald's and third-party advertising networks, with the additional disclosure that targeting cookies may view, edit, or set other third-party cookies in the user's browser.
Under this clause, McDonald's and its advertising partners may use targeting cookies to build interest-based profiles and track online activity across third-party websites and devices over time. Consumers can decline targeting cookies through the McDonald's Cookie Settings Tool, browser controls, or by activating the Global Privacy Control signal.
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"Targeting Cookies: These cookies may be set through our online services by us or our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on other sites. These advertisements may also place cookies that can view, edit, or set other third-party cookies in your web browser. We and selected third parties (such as our advertising networks) may use these technologies to collect information about your online activities, over time and across third-party websites and devices, and when using our online services to further personalize your experience with us.Excerpt from McDonald's's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages the EU ePrivacy Directive (and national implementing laws) regarding consent for non-essential cookies, GDPR requirements for valid consent to behavioral advertising, and CCPA or CPRA provisions on sharing personal information for cross-context behavioral advertising. The FTC Act engages this provision with respect to cross-context tracking disclosures. Relevant enforcement authorities include EU national data protection authorities, the California Privacy Protection Agency, and the FTC. 2. GOVERNANCE EXPOSURE: Medium. The disclosure that targeting cookies may view, edit, or set other third-party cookies is operationally significant and may require evaluation under ePrivacy and GDPR consent standards, particularly regarding whether the consent obtained through the Cookie Settings Tool covers this breadth of third-party cookie interaction. The cross-device and cross-site tracking scope requires ongoing vendor management. 3. JURISDICTION FLAGS: EU and EEA jurisdictions require opt-in consent for non-essential cookies under the ePrivacy Directive, meaning targeting cookies cannot be set without valid prior consent. California requires opt-out mechanisms for sharing with advertising partners and GPC signal compliance. The UK post-Brexit cookie consent framework creates parallel obligations. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising network partners who set targeting cookies through McDonald's online services should be identified and assessed for compliance with applicable consent and data use limitations. The ability of these cookies to interact with other third-party cookies in the browser creates downstream data flow complexity that vendor agreements should address. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the Cookie Settings Tool to confirm it presents a genuine opt-in mechanism for EU users (not a pre-checked or default-enabled targeting cookie setting), and that opt-out preferences are technically enforced across all McDonald's online services. The GPC signal processing described in Section 5 should be confirmed as applying to advertising cookie sharing as well as other sale and sharing contexts.
This provision authorizes cross-site and cross-device behavioral tracking for advertising purposes by McDonald's and third-party advertising networks, with the additional disclosure that targeting cookies may view, edit, or set other third-party cookies in the user's browser.
Under this clause, McDonald's and its advertising partners may use targeting cookies to build interest-based profiles and track online activity across third-party websites and devices over time. Consumers can decline targeting cookies through the McDonald's Cookie Settings Tool, browser controls, or by activating the Global Privacy Control signal.
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