The policy states that Meta receives behavioral and transaction data from third-party data providers and from partner websites and apps through Meta's business tools such as Meta Pixel and Conversions API, and that Meta requires partners to have a lawful basis for sharing that data.
This analysis describes what Meta Ads'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 Meta's data collection extends beyond its own products to include off-platform browsing, purchase, and behavioral data sourced from third parties, which is incorporated into user profiles used for advertising and personalization across Meta's services.
The updated Privacy Policy no longer explicitly directs US residents to the United States Regional Privacy Notice, which previously provided details about consumer privacy rights available under state laws like the California Consumer Privacy Act and similar regulations. This removal does not eliminate those rights themselves, but it makes the Privacy Policy less clear about where consumers can find information on how to exercise those rights. Consumers can still locate the Regional Privacy Notice through Meta's website or by searching for it directly, but the removal reduces the accessibility and prominence of that guidance within the primary policy document.
View change record →Under this clause, data about a user's activity on third-party websites and apps, including potential purchase transactions, is shared with Meta by those third-party operators and incorporated into the user's Meta advertising profile, even when the user is not actively using a Meta product.
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At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information. Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.— Excerpt from Meta Ads's Meta Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14 (transparency obligations for data obtained from third parties), as well as the ePrivacy Directive as applied to cookie and pixel-based tracking. The Irish DPC and other EU supervisory authorities have scrutinized whether users receive adequate notice of third-party data flows to Meta. CCPA/CPRA provisions on data brokers and third-party data sharing are also implicated. The FTC has issued guidance on data broker practices relevant to Meta's data provider relationships. (2) GOVERNANCE EXPOSURE: High. The use of third-party data provider relationships to supplement Meta's own data for advertising creates a complex data supply chain that may implicate joint controller, processor, and data broker frameworks depending on jurisdiction and the specific data flow. (3) JURISDICTION FLAGS: EU and EEA users have rights under GDPR Article 14 to receive notice when their data is obtained from third parties; whether Meta's policy-level disclosure satisfies this obligation individually is subject to regulatory interpretation. California users have CPRA-based rights to know the categories of third-party sources from which their data is collected. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations that implement Meta Pixel, Meta SDK, or server-side Conversions API on their platforms are the upstream source of data flowing to Meta under this provision. Their own terms of service and privacy disclosures to end users should account for this downstream data flow, and their agreements with Meta should be reviewed for liability allocation related to lawful basis assertions. (5) COMPLIANCE CONSIDERATIONS: Organizations using Meta's advertising and analytics tools should conduct a data flow mapping exercise to identify all data transmitted to Meta through business tool implementations and assess whether their own privacy notices adequately disclose these transfers. EU-based organizations should evaluate whether a Data Protection Impact Assessment is required and whether Standard Contractual Clauses or other transfer mechanisms are in place for any international data transfer component.
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This provision establishes that Meta's data collection extends beyond its own products to include off-platform browsing, purchase, and behavioral data sourced from third parties, which is incorporated into user profiles used for advertising and personalization across Meta's services.
Under this clause, data about a user's activity on third-party websites and apps, including potential purchase transactions, is shared with Meta by those third-party operators and incorporated into the user's Meta advertising profile, even when the user is not actively using a Meta product.
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