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The statement authorizes Palantir to generate inferred data by combining internally collected data with third-party partner and publicly available data, and to use this inferred data along with other collected categories to place targeted advertisements on third-party platforms including LinkedIn and Twitter.
This analysis describes what Palantir'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 inferred data, derived from combining multiple internally collected categories with external third-party data, is used as an input for behavioral advertising on external social media and search platforms. The provision relies on legitimate interests as the legal basis for this processing in the EEA, UK, and Switzerland context, which may require evaluation under applicable regulatory guidance on behavioral advertising.
Interpretive note: The enforceability and regulatory acceptability of legitimate interests as the legal basis for behavioral advertising profiling varies by EU member state and is subject to evolving regulatory guidance.
The updated Privacy Statement now authorizes Palantir to disclose personal data to promotional code partners who may then contact you if you sign up for a Palantir service using their code. This establishes a new third-party contact pathway not previously disclosed in the policy. The terms do not specify how frequently partners may contact you, what data is included in the disclosure, or whether you can opt out of partner contact after signing up.
View change record →Under this provision, Palantir may combine data collected across multiple touchpoints with third-party data to generate preference and interest profiles used for targeted advertising on platforms including LinkedIn and Twitter. Individuals in EEA, UK, or Swiss jurisdictions may object to this processing by contacting privacy@palantir.com.
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"Inferred Data: Preferences, likelihood of interest in Palantir products and/or services. Data generated by combining data (such as Contact Data, Professional Data, Transaction Data, Technical Data and Communication Data) collected by Palantir with information obtained from third parties (such as Contact Data, Professional Data, Transaction Data, Technical Data and Communication Data), including partners and publicly available sources, which assist with the sale of products or services, compliance with laws, and that detect, prevent and otherwise address fraudulent, deceptive, or illegal activity. To target advertising: We use your Contact Data, Professional Data, Communication Data, Technical Data, Transaction Data, Training and Educational Data, and Inferred Data to target advertisements and messages to you, this can include targeted advertising via third party advertising platforms including search engines and social media/networking platforms such as LinkedIn or Twitter.Excerpt from Palantir's Privacy Statement
1. REGULATORY LANDSCAPE: This provision implicates GDPR Article 6(1)(f) (legitimate interests) and, where applicable, ePrivacy Directive requirements for behavioral advertising. In the US context, CCPA and applicable state privacy laws may impose disclosure and opt-out obligations for processing personal information for targeted advertising purposes. The FTC exercises general oversight over unfair or deceptive data practices. EU data protection authorities and the UK ICO have issued guidance constraining the use of legitimate interests for behavioral advertising, and this provision should be evaluated against that guidance. 2. GOVERNANCE EXPOSURE: Medium. The provision authorizes profiling by combining multiple data categories with third-party data for advertising purposes and relies on legitimate interests rather than consent as the primary legal basis in the EU/UK context. Regulatory enforcement posture in several EU jurisdictions has placed constraints on this approach for behavioral advertising, creating compliance exposure that depends on jurisdiction and enforcement context. 3. JURISDICTION FLAGS: EEA member states, the UK, and California create heightened exposure. Several EU data protection authorities have found that legitimate interests does not provide a sufficient legal basis for behavioral advertising profiling in certain contexts. California residents may have opt-out rights for use of personal information for targeted advertising under CCPA as amended. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations contracting with Palantir for training or events should assess whether their employees' data being processed for inferred profiling and advertising purposes is consistent with their own privacy obligations to employees. The document does not specify contractual limits on third-party advertising platform data use once pseudonymous data is disclosed to those platforms. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the legitimate interests balancing test is documented and defensible for behavioral advertising profiling under GDPR; whether consent mechanisms are in place for jurisdictions where consent is required for this processing; and whether opt-out mechanisms for targeted advertising satisfy applicable US state privacy law requirements.
This provision establishes that inferred data, derived from combining multiple internally collected categories with external third-party data, is used as an input for behavioral advertising on external social media and search platforms. The provision relies on legitimate interests as the legal basis for this processing in the EEA, UK, and Switzerland context, which may require evaluation under applicable regulatory guidance …
Under this provision, Palantir may combine data collected across multiple touchpoints with third-party data to generate preference and interest profiles used for targeted advertising on platforms including LinkedIn and Twitter. Individuals in EEA, UK, or Swiss jurisdictions may object to this processing by contacting privacy@palantir.com.
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