Microsoft · Microsoft Privacy Statement (Legacy) · View original document ↗

Data Sharing with Third Parties

Medium severity High confidence Explicitdocumentlanguage Rare · 6 of 325 platforms
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Recent governance activity Microsoft recorded 3 documented changes in the last 30 days.
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Document Record

What it is

Microsoft shares your personal data with affiliated companies, vendors working on its behalf, and others including in response to legal requirements or in connection with corporate transactions such as mergers or acquisitions. Some sharing requires your consent; other sharing occurs without it under the described conditions.

This analysis describes what Microsoft'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The statement identifies multiple categories of third parties with whom personal data may be shared, including affiliates, service vendors, and parties in legal or corporate transaction contexts, which determines the breadth of entities that may access user data.

Recent Activity

This document changed recently

Medium Apr 19, 2026

The updated policy establishes additional grounds on which Microsoft may retain personal data. While the prior version tied retention to specific user expectations and available deletion controls, th…

Medium Apr 1, 2026

The updated policy now grounds data retention in five broad business purposes: operating the business, meeting contractual and legal obligations, improving and developing products and services, prote…

Medium Mar 13, 2026

The updated Privacy Statement removes previously stated language about additional rights available to European Economic Area users, narrowing the policy's explicit protections in that region. Simulta…

Consumer impact (what this means for users)

Your personal data collected through Microsoft products may be shared with Microsoft subsidiaries, service providers, and others in circumstances including legal compliance and corporate transactions. Users seeking to understand who receives their data can review the statement's list of sharing categories.

How other platforms handle this

Revolut Medium

When you ask us to open an Account, we or someone acting for us will ask for information about you and where the money you will put in your Account comes from. We do this for a number of reasons, including to check your credit score and identity, and to meet our legal and regulatory requirements. Ou...

Wise Medium

We may share your personal information with third parties, including service providers, financial institutions, regulatory authorities, and fraud prevention agencies, where necessary to provide our services, comply with legal obligations, or protect against fraud and financial crime.

Lime Medium

We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...

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▸ View Original Clause Language DOCUMENT RECORD
"
We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We also share data with Microsoft-controlled affiliates and subsidiaries; with vendors or agents working on our behalf; when required by law or to respond to legal process; to protect the rights or property of Microsoft or our customers, including enforcing the agreements governing the use of the services; and in connection with a merger, acquisition, or sale of assets.

— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Third-party data sharing engages GDPR requirements on data transfers to third parties including processors and controllers, and EU standard contractual clauses for international transfers; CCPA requirements on disclosure of third-party sharing categories and opt-out rights for sharing constituting a sale; and FTC Act requirements on accuracy of sharing representations. Enforcement authorities include EU data protection authorities, the California Privacy Protection Agency, and the FTC. GOVERNANCE EXPOSURE: Medium. The statement's description of sharing categories is broad; compliance teams must assess whether specific sharing arrangements are covered by appropriate contractual protections, including data processing agreements for vendors and standard contractual clauses for international transfers. JURISDICTION FLAGS: GDPR Chapter V requirements for international data transfers apply where data is transferred outside the EU and EEA. CCPA requires disclosure of specific categories of third parties to whom personal information is disclosed. The merger and acquisition carve-out for data sharing is standard but warrants monitoring in the event of a significant corporate transaction. CONTRACT AND VENDOR IMPLICATIONS: Organizations using Microsoft as a vendor should assess whether data processing agreements adequately address sub-processor relationships implied by the vendor sharing described in this provision. Sub-processor lists and notification obligations should be reviewed. COMPLIANCE CONSIDERATIONS: Compliance teams should maintain a current sub-processor and third-party sharing inventory aligned with this provision; verify that international transfer mechanisms (standard contractual clauses or equivalent) are in place; and assess whether the merger and acquisition sharing carve-out requires notification obligations under applicable law.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over data sharing practices and representations made to consumers about how their data is shared with third parties.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Document last updated
March 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 12, 2026
Record ID
CA-P-010870
Document ID
CA-D-00001
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9e697464d17b7148c787f07099c60e30370abb2b13a7f2a910f607e31ec13158
Analysis generated
April 28, 2026 08:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-P-010870
Captured: 2026-04-28 08:11:57 UTC
SHA-256: 9e697464d17b7148…
URL: https://conductatlas.com/platform/microsoft/microsoft-privacy-statement-legacy/data-sharing-with-third-parties/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Microsoft's Data Sharing with Third Parties clause do?

The statement identifies multiple categories of third parties with whom personal data may be shared, including affiliates, service vendors, and parties in legal or corporate transaction contexts, which determines the breadth of entities that may access user data.

How does this clause affect you?

Your personal data collected through Microsoft products may be shared with Microsoft subsidiaries, service providers, and others in circumstances including legal compliance and corporate transactions. Users seeking to understand who receives their data can review the statement's list of sharing categories.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.

Is ConductAtlas affiliated with Microsoft?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Microsoft.