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The policy states that Meta shares user data with advertisers, measurement partners, and analytics companies to support ad targeting, campaign measurement, and reporting, and that advertisers may also supply additional user identifiers to Meta for audience matching and targeting purposes.
This analysis describes what Meta'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 a bidirectional data flow in which Meta both shares user data with advertising partners and receives supplemental user data from those partners for audience matching, creating a data exchange that informs ad targeting and campaign performance measurement.
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, information including email addresses and phone numbers may be shared between Meta and advertisers for ad targeting and audience matching purposes, and aggregate user data is shared with analytics partners who provide measurement reporting to Meta's advertising clients.
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Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
In some cases, in order to show you more relevant ads, we disclose with social media platforms and other advertising partners, information about actions you take on our websites and apps, such as which pages you visit and which ads you saw.
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"We share information about you with advertisers, measurement and analytics partners, and other partners who help us improve our advertising and measurement systems. Advertisers and other advertising partners who buy ads through Meta's advertising tools can tell us information about you, such as your email address or phone number, to customise or improve their ad targeting. We share your information with companies that aggregate it to provide analytics and measurement reports to our partners.Excerpt from Meta's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 6, 13, and 28 regarding lawful basis for sharing, transparency, and data processing agreements with partners. CCPA/CPRA provisions on sale and sharing of personal information with third parties for cross-context behavioral advertising are directly implicated. FTC Act Section 5 standards on consumer notice and consent for data sharing with advertising partners apply in the US context. (2) GOVERNANCE EXPOSURE: High. The combination of outbound user data sharing with advertisers and inbound advertiser-supplied identifier data creates significant compliance surface area, particularly regarding whether adequate consent or legal basis exists for each directional data flow and whether joint controller relationships are properly documented. (3) JURISDICTION FLAGS: California users have CPRA opt-out rights for sharing personal information with third parties for cross-context behavioral advertising. EU users have GDPR transparency and consent rights. The sharing of hashed identifiers such as email addresses and phone numbers with advertisers may require evaluation under applicable data minimization and purpose limitation principles. (4) CONTRACT AND VENDOR IMPLICATIONS: Advertisers using Meta's Custom Audiences or similar matching tools are contractually required by Meta's terms to have a lawful basis for the user data they upload. Procurement teams at organizations using these tools should confirm that their internal consent mechanisms and data use disclosures cover the sharing of customer email addresses and phone numbers with Meta for audience matching. (5) COMPLIANCE CONSIDERATIONS: Legal teams should review whether Meta's advertiser data upload tools are covered by a Data Processing Agreement or Custom Audiences Terms that satisfy GDPR Article 28 requirements. California compliance teams should confirm whether the sharing described in this provision requires a CPRA opt-out mechanism and whether Meta's opt-out tools are surfaced adequately to California users.
Regulatory citations, enforcement risk, and due diligence action items.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes a bidirectional data flow in which Meta both shares user data with advertising partners and receives supplemental user data from those partners for audience matching, creating a data exchange that informs ad targeting and campaign performance measurement.
Under this clause, information including email addresses and phone numbers may be shared between Meta and advertisers for ad targeting and audience matching purposes, and aggregate user data is shared with analytics partners who provide measurement reporting to Meta's advertising clients.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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