The policy authorizes disclosure of user personal data to third parties in connection with corporate transactions including mergers, asset sales, financing events, or acquisitions, including during negotiation phases.
This analysis describes what OpenRouter'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 may be transferred to prospective acquirers or transaction counterparties prior to completion of a corporate transaction, without individualized user consent at the time of transfer.
Language simplified and narrowed: previous version detailed specific scenarios (bankruptcy, receivership, asset transition) and mentioned 'sold or transferred,' while current version uses more general 'share' language and removes references to bankruptcy and service transitions.
View full change record →Under this clause, personal data including account information, transaction history, and behavioral data may be disclosed to third parties during due diligence or financing processes, and may transfer to a new controlling entity upon completion of an acquisition or asset sale.
How other platforms handle this
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...
We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...
Monitoring
OpenRouter has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"We may share your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.— Excerpt from OpenRouter's OpenRouter Privacy Policy
REGULATORY LANDSCAPE: GDPR requires that data transfers in connection with corporate transactions maintain a lawful basis and that data subjects be informed of changes to the controller's identity. CCPA requires disclosure of whether personal information is sold or disclosed as part of a business transfer and preserves opt-out rights. The FTC has addressed data transfers in corporate transactions in prior enforcement actions involving changes to privacy practices post-acquisition. GOVERNANCE EXPOSURE: Medium. The inclusion of pre-transaction negotiations as a permissible disclosure event is operationally significant, as it extends personal data access to parties who may not ultimately complete the transaction. Standard commercial practice includes data room protections such as non-disclosure agreements, but the policy does not specify such safeguards. JURISDICTION FLAGS: EU users have heightened exposure given GDPR controller change notification requirements. California users retain CCPA rights following a business transfer, but practical enforcement against a new entity may require additional steps. The policy does not address user notification timelines in the event a transaction closes. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess whether their agreements with OpenRouter include data transfer restrictions in connection with corporate transactions, and whether a change of control clause is warranted. B2B contracts may need to address continuity of data processing obligations following an acquisition. COMPLIANCE CONSIDERATIONS: Compliance teams should monitor for announced corporate transactions involving OpenRouter and evaluate whether post-transaction data practices remain consistent with representations made at the time of data collection. User notification obligations in the event of a transaction should be assessed under applicable jurisdiction requirements.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision establishes that personal data may be transferred to prospective acquirers or transaction counterparties prior to completion of a corporate transaction, without individualized user consent at the time of transfer.
Under this clause, personal data including account information, transaction history, and behavioral data may be disclosed to third parties during due diligence or financing processes, and may transfer to a new controlling entity upon completion of an acquisition or asset sale.
ConductAtlas has identified this type of provision across 10 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenRouter.