Palantir uses 'legitimate interests' — a legal basis under GDPR — to justify processing your personal data for marketing and analytics without requiring your explicit consent.
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
Legitimate interests is a flexible but contestable lawful basis; individuals in the EU and UK have the right to object to processing conducted on this basis, and Palantir must stop if it cannot demonstrate compelling grounds that override those interests.
Interpretive note: The specific balancing tests Palantir has conducted for each legitimate interests claim are not disclosed in the document, making it unclear whether the assertions would withstand regulatory scrutiny under GDPR Article 6(1)(f).
Your contact information and browsing behavior may be processed for Palantir's marketing and analytics purposes without your affirmative consent, based on Palantir's assertion of legitimate business interests. EU and UK residents can object to this processing by contacting privacy@palantir.com.
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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...
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"We process your personal data on the basis of our legitimate interests, where those interests are not overridden by your rights and interests. We rely on legitimate interests for processing activities such as marketing our products and services, improving our website and services, and conducting analytics.— Excerpt from Palantir's Palantir Privacy Statement
REGULATORY LANDSCAPE: The legitimate interests basis engages GDPR Article 6(1)(f), which requires a three-part balancing test: the legitimate interest must be identified, the processing must be necessary for that purpose, and the interest must not be overridden by the data subject's interests or fundamental rights. EU supervisory authorities — particularly the Irish DPC and German Datenschutzbehörden — have scrutinized legitimate interests claims in digital marketing and analytics contexts. The UK ICO has published guidance indicating that marketing and analytics uses of legitimate interests require careful balancing documentation. GOVERNANCE EXPOSURE: Medium. The reliance on legitimate interests for marketing activities has been the subject of enforcement action in various EU jurisdictions. If Palantir's legitimate interests assessments are not adequately documented in a Legitimate Interests Assessment (LIA), the lawful basis claim may be vulnerable to regulatory challenge. The statement does not reference LIAs or describe the balancing test conducted. JURISDICTION FLAGS: EU and UK residents are most directly affected given the GDPR and UK GDPR Article 6(1)(f) requirements. In California, the CCPA/CPRA framework does not use a 'legitimate interests' concept but does require opt-out rights for certain data sales and sharing for cross-context behavioral advertising, which may overlap with analytics use cases. CONTRACT AND VENDOR IMPLICATIONS: B2B counterparties whose employee contact data Palantir holds as part of business development activities should assess whether their own privacy notices adequately disclose Palantir as a data recipient and whether employee consent or legitimate interests documentation is in place on their side. COMPLIANCE CONSIDERATIONS: Palantir's legal team should maintain documented Legitimate Interests Assessments for each processing activity relying on Article 6(1)(f), make these available to supervisory authorities on request, and ensure that the right to object under GDPR Article 21 is clearly communicated to data subjects — including the mechanism for exercising that right.
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Legitimate interests is a flexible but contestable lawful basis; individuals in the EU and UK have the right to object to processing conducted on this basis, and Palantir must stop if it cannot demonstrate compelling grounds that override those interests.
Your contact information and browsing behavior may be processed for Palantir's marketing and analytics purposes without your affirmative consent, based on Palantir's assertion of legitimate business interests. EU and UK residents can object to this processing by contacting privacy@palantir.com.
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