OpenSea · OpenSea Privacy Policy · View original document ↗

Corporate Restructuring Data Transfer

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Document Record

What it is

The policy states that personal information may be shared or transferred to third parties during merger, acquisition, financing, dissolution, bankruptcy, or receivership proceedings, and that an acquiring company will assume OpenSea's privacy rights and obligations.

This analysis describes what OpenSea'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)

This provision authorizes disclosure of personal information during corporate transaction negotiations as well as full transfer in the event of acquisition or insolvency. The policy asserts that an acquiring entity assumes the rights and obligations of the current privacy policy, though regulatory frameworks may impose additional requirements on such transfers depending on jurisdiction.

Interpretive note: The scope of data shared during transaction negotiations versus upon completion is not specified, and the enforceability of the acquiring company's assumption of privacy obligations depends on applicable law and transaction terms.

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, personal information may be shared with prospective acquirers during deal negotiations and transferred to an acquiring entity upon completion. The agreement states the acquiring company will be bound by this Privacy Policy, though the practical enforceability of this assertion depends on applicable law and the terms of any acquisition.

Cross-platform context

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Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
we may share some or all of your information and information about you in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving a sale, transfer, or divestiture of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your information and information about you may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the information collected by us and will assume the rights and obligations regarding your information and information about you as described in this Privacy Policy.

Excerpt from OpenSea's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14 (transparency about data recipients), CCPA disclosure requirements, and applicable insolvency law. GDPR requires that data subjects be informed of new controllers following a transfer. The FTC has addressed privacy representations in corporate transactions in prior enforcement actions. (2) GOVERNANCE EXPOSURE: Medium. The authorization to share data during transaction negotiations is broadly stated and does not specify what data is shared, with whom, or under what confidentiality or data processing protections, which may require evaluation under GDPR. (3) JURISDICTION FLAGS: EEA and UK users have heightened exposure, as GDPR requires controller-to-controller transfers to have an appropriate legal basis and transparency. In insolvency scenarios, the treatment of personal data as a business asset may interact with GDPR requirements. California users under CCPA have disclosure rights regarding new controllers upon acquisition. (4) CONTRACT AND VENDOR IMPLICATIONS: Institutional users should assess whether their data may be accessible to prospective acquirers during due diligence, and whether confidentiality protections are specified in OpenSea's transaction procedures. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the policy's treatment of data as transferable in insolvency proceedings is consistent with GDPR requirements for controller succession, and whether user notification obligations arise upon completion of a qualifying transaction.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over privacy representations in corporate transactions and the treatment of consumer data assets in acquisitions and insolvency proceedings
    File a complaint →

Provision details

Document information
Document
OpenSea Privacy Policy
Entity
OpenSea
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014831
Document ID
CA-D-00210
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3401c3c3ce9929583cb3d2d39dfd1d62dd13b5de1dec21c748453ae7951b76d6
Analysis generated
July 9, 2026 06:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenSea
Document: OpenSea Privacy Policy
Record ID: CA-P-014831
Captured: 2026-07-09 06:33:11 UTC
SHA-256: 3401c3c3ce992958…
URL: https://conductatlas.com/platform/opensea/opensea-privacy-policy/provision/CA-P-014831/corporate-restructuring-data-transfer/
Accessed: July 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenSea's Corporate Restructuring Data Transfer clause do?

This provision authorizes disclosure of personal information during corporate transaction negotiations as well as full transfer in the event of acquisition or insolvency. The policy asserts that an acquiring entity assumes the rights and obligations of the current privacy policy, though regulatory frameworks may impose additional requirements on such transfers depending on jurisdiction.

How does this clause affect you?

Under this clause, personal information may be shared with prospective acquirers during deal negotiations and transferred to an acquiring entity upon completion. The agreement states the acquiring company will be bound by this Privacy Policy, though the practical enforceability of this assertion depends on applicable law and the terms of any acquisition.

Is ConductAtlas affiliated with OpenSea?

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