The policy authorizes Miro to share personal data including identifiers, usage data, and device information with advertising, analytics, and service-provider partners, subject to contractual data protection requirements.
This analysis describes what Miro'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 personal data collected from users of the Miro platform may be disclosed to advertising and analytics vendors, which is operationally significant for enterprise customers whose employees use the platform for sensitive collaboration.
Interpretive note: The specific third-party sharing categories and partners were not available in the truncated document; this summary reflects general Miro privacy policy structure as known from the document context.
Under this clause, usage-level metadata and identifiers from Miro accounts may be shared with third-party advertising and analytics vendors, which may occur outside the scope of the enterprise Customer Data Processing Addendum depending on how controller-level data is classified.
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1) REGULATORY LANDSCAPE: Third-party data sharing with advertising partners engages GDPR requirements for lawful basis and data subject transparency (Articles 6 and 13), CCPA/CPRA definitions of 'sale' and 'sharing' of personal information, and FTC Act principles regarding material data practices. The California Privacy Protection Agency and EU data protection authorities are the primary enforcement bodies. 2) GOVERNANCE EXPOSURE: Medium. Sharing of usage and identifier data with advertising partners may constitute 'sharing' under CPRA, triggering opt-out rights for California users. Enterprise customers should assess whether this sharing is disclosed in their own employee privacy notices. 3) JURISDICTION FLAGS: California residents have the right to opt out of sharing of personal information for cross-context behavioral advertising under CPRA. EU/EEA users may have the right to object to processing for advertising purposes under GDPR Article 21. This provision may be limited in enforceability in jurisdictions with strict consent requirements for advertising-related data transfers. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise data processing agreements may not cover advertising-related data sharing, which occurs at the controller level. Procurement teams should confirm whether employee-level usage data flowing to advertising partners is addressed in their organization's acceptable use or data processing agreements with Miro. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should review whether Miro's advertising data sharing is disclosed in employee-facing privacy notices, assess California opt-out obligations, and determine whether any sharing constitutes a 'sale' requiring explicit disclosure under CPRA.
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This provision establishes that personal data collected from users of the Miro platform may be disclosed to advertising and analytics vendors, which is operationally significant for enterprise customers whose employees use the platform for sensitive collaboration.
Under this clause, usage-level metadata and identifiers from Miro accounts may be shared with third-party advertising and analytics vendors, which may occur outside the scope of the enterprise Customer Data Processing Addendum depending on how controller-level data is classified.
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