OpenSea · OpenSea Privacy Policy · View original document ↗

Corporate Transaction Data Transfer

Medium severity Medium confidence Inferredfromcontext Uncommon · 23 of 343 platforms
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Document Record

What it is

The policy states that personal data may be transferred to a successor entity in connection with a merger, acquisition, bankruptcy, or sale of all or substantially all of OpenSea's assets.

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 reserves the right to transfer all collected personal data to a third party in the event of a corporate transaction, which may result in user data being governed by a different privacy policy without additional consent being obtained prior to transfer.

Interpretive note: Exact verbatim text was not fully extractable from the rendered HTML; description reflects standard corporate transaction clause language commonly found in OpenSea's published policy.

Consumer impact (what this means for users)

Under this provision, personal data collected by OpenSea including wallet addresses, transaction history, and communications data may be transferred to an acquiring entity whose privacy practices may differ from OpenSea's current policy. The policy states that users will be notified of such transfers where required by applicable law.

How other platforms handle this

Discord Medium

We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or dissolution, transaction, or proceeding involving all or a portion of our business.

Figma Medium

By using our Services, you agree to be bound by this Privacy Policy.

MetaMask Medium

We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.

See all platforms with this clause type →

Monitoring

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Corporate transaction data transfer clauses implicate GDPR Article 6 lawful basis requirements and may require a new privacy notice or consent for EEA users if the acquiring entity's processing purposes differ materially. CCPA similarly requires disclosure of data transfers. The FTC has historically reviewed data transfer representations in corporate transactions. (2) GOVERNANCE EXPOSURE: Medium. The breadth of the corporate transfer authorization is standard in U.S. consumer contracts, but EEA and UK requirements impose additional obligations on change-of-controller scenarios. If an acquisition results in a change of data controller, GDPR may require user notification and potentially new consent. (3) JURISDICTION FLAGS: EEA and UK users face the highest exposure under GDPR and UK GDPR change-of-controller notification requirements. California residents may have rights under CCPA if a transfer to a new entity results in materially different data use. Jurisdictions with data localization requirements may restrict cross-border data transfers in acquisition scenarios. (4) CONTRACT AND VENDOR IMPLICATIONS: Acquirers conducting due diligence on OpenSea should assess the volume and categories of personal data subject to transfer and evaluate whether the acquiring entity's privacy practices can accommodate GDPR and CCPA obligations for the inherited user base. Data processing agreements should be reviewed for assignment provisions. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the corporate transfer clause includes adequate user notification commitments for EEA users where a change of controller occurs, and whether the clause specifies that the acquiring entity must honor existing privacy commitments. Review of data inventory and data processing agreements should be triggered in anticipation of any corporate transaction.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC reviews representations about data practices in corporate transactions and has authority over consumer data handling under the FTC Act
    File a complaint →

Applicable regulations

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

Provision details

Document information
Document
OpenSea Privacy Policy
Entity
OpenSea
Document last updated
May 5, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-012324
Document ID
CA-D-00210
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d37e2af14a3dca7a93223394af3650a3b5b4596263f707caffb7c79769c9c586
Analysis generated
May 20, 2026 20:03 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenSea
Document: OpenSea Privacy Policy
Record ID: CA-P-012324
Captured: 2026-05-20 20:03:59 UTC
SHA-256: d37e2af14a3dca7a…
URL: https://conductatlas.com/platform/opensea/opensea-privacy-policy/corporate-transaction-data-transfer/
Accessed: June 8, 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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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

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

This provision reserves the right to transfer all collected personal data to a third party in the event of a corporate transaction, which may result in user data being governed by a different privacy policy without additional consent being obtained prior to transfer.

How does this clause affect you?

Under this provision, personal data collected by OpenSea including wallet addresses, transaction history, and communications data may be transferred to an acquiring entity whose privacy practices may differ from OpenSea's current policy. The policy states that users will be notified of such transfers where required by applicable law.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 23 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenSea?

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