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The agreement discloses that Mixpanel's use of interest-based advertising services may constitute CCPA 'sharing' of Identifiers and Internet or Network Information with advertising partners, from which California residents may opt out; the agreement separately states Mixpanel does not 'sell' Personal Information under the CCPA definition.
This analysis describes what Mixpanel'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 operationalizes CCPA opt-out rights for cross-contextual behavioral advertising sharing, including GPC signal compliance, and distinguishes between 'sharing' (disclosed as occurring) and 'selling' (asserted as not occurring) under CCPA definitions. The distinction is legally significant for California residents' opt-out rights and enforcement scope.
Under this clause, California residents may opt out of the sharing of their Identifiers and Internet or Network Information with advertising partners by using the 'Your Privacy Choices' footer link or by configuring a Global Privacy Control browser signal. The opt-out applies per browser and per device from which the request is submitted.
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"Our use of the interest-based advertising services described above may constitute 'sharing' of your Personal Information with our advertising partners from which you have the right to opt-out under the CCPA. You can request to opt-out of this 'sharing' as detailed above. The categories of Personal Information shared include Identifiers and Internet or Network Information as described in the CCPA. As stated above, we do not 'sell' Personal Information as defined by the CCPA.Excerpt from Mixpanel's Privacy Statement
(1) REGULATORY LANDSCAPE: This provision directly engages the California Consumer Privacy Act as amended by CPRA, including the definition of 'sharing' for cross-contextual behavioral advertising and associated opt-out rights. The California Privacy Protection Agency and California Attorney General have enforcement authority. GPC signal compliance is addressed by CPPA enforcement guidance. The FTC Act also applies to deceptive advertising data practices. (2) GOVERNANCE EXPOSURE: Low to Medium. The disclosure is explicit and the opt-out mechanism is described. The browser-and-device-specific scope of the opt-out request, rather than an account-level opt-out, is a material operational limitation that users should be aware of. Businesses using Mixpanel for advertising analytics should confirm that their own CCPA notices disclose Mixpanel as a data sharing partner for advertising purposes. (3) JURISDICTION FLAGS: This provision applies exclusively to California residents under CCPA. Other US state privacy laws with similar 'sharing' or targeted advertising opt-out provisions may create analogous obligations in Virginia, Colorado, Connecticut, and other states with comprehensive privacy statutes, though the document does not address those states expressly. (4) CONTRACT AND VENDOR IMPLICATIONS: Businesses using Mixpanel's advertising analytics integrations should assess whether their vendor agreements with Mixpanel address the 'sharing' designation and whether their own consumer-facing privacy disclosures are synchronized with Mixpanel's disclosed data sharing categories. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the 'Your Privacy Choices' opt-out link is implemented and functional on all Mixpanel-governed web properties; confirm GPC signal processing is active and auditable; and assess whether the browser-device scope limitation of opt-out requests is disclosed in a manner consistent with CPPA guidance on opt-out mechanisms.
This provision operationalizes CCPA opt-out rights for cross-contextual behavioral advertising sharing, including GPC signal compliance, and distinguishes between 'sharing' (disclosed as occurring) and 'selling' (asserted as not occurring) under CCPA definitions. The distinction is legally significant for California residents' opt-out rights and enforcement scope.
Under this clause, California residents may opt out of the sharing of their Identifiers and Internet or Network Information with advertising partners by using the 'Your Privacy Choices' footer link or by configuring a Global Privacy Control browser signal. The opt-out applies per browser and per device from which the request is submitted.
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