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The statement establishes that Palantir may send marketing communications and conduct personalization profiling on the basis of legitimate interests in jurisdictions where consent has not been separately sought, in addition to consent-based marketing where consent is obtained.
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 a dual legal basis structure for marketing communications and personalization profiling: consent where obtained, and legitimate interests where consent has not been separately sought. This means Palantir may send marketing communications without prior consent in contexts where legitimate interests is asserted as the applicable basis, subject to the right to object.
Interpretive note: The enforceability of legitimate interests as a basis for unsolicited electronic marketing varies by EU member state and depends on the applicable national implementation of the ePrivacy Directive.
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, individuals in EEA, UK, and Swiss contexts may receive marketing communications and be subject to personalization profiling without prior consent where Palantir relies on legitimate interests. Individuals have the right to object to this processing by contacting privacy@palantir.com or using the unsubscribe mechanism in communications.
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"To send sales and marketing communications: Your consent. When we communicate with you for the purposes of marketing, we may do this on the basis of your consent, which you may revoke at any time. Our legitimate interests. If we have not asked for your consent, we might send you marketing communications on the basis of Palantir's legitimate interest in marketing our products and services. To understand who would be most interested in our products and services and to personalize our communications: Our legitimate interests. If we have not asked for your consent, we might process your personal data to deliver relevant advertising communications to you on the basis of Palantir's legitimate interest in marketing our products and services.Excerpt from Palantir's Privacy Statement
1. REGULATORY LANDSCAPE: The use of legitimate interests for unsolicited marketing communications may require evaluation under GDPR and the ePrivacy Directive, as well as applicable national marketing law implementations. Several EU member state data protection authorities and the UK ICO have published guidance on when legitimate interests may be relied upon for direct marketing. The FTC and US state regulators apply separate frameworks for electronic marketing under the CAN-SPAM Act and applicable state law. 2. GOVERNANCE EXPOSURE: Medium. The provision explicitly acknowledges that marketing may proceed without prior consent on a legitimate interests basis. The balancing test documentation required under GDPR and the operational procedures for honoring objection requests are not described in the document, creating compliance implementation questions. 3. JURISDICTION FLAGS: EEA and UK jurisdictions create heightened exposure. The ePrivacy Directive's requirements for electronic marketing consent, and national implementations thereof, may constrain the use of legitimate interests for certain forms of electronic direct marketing. Germany, France, and the Netherlands have historically applied stricter standards in this area. 4. CONTRACT AND VENDOR IMPLICATIONS: B2B contacts at organizations engaging with Palantir commercially should assess whether their employer's email communication policies and applicable law permit unsolicited marketing on a legitimate interests basis in their jurisdiction. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should review whether legitimate interests balancing tests are documented for marketing activities, whether opt-out mechanisms are technically functional and operationally monitored, and whether the dual consent/legitimate interests structure is consistently applied across different marketing channels and jurisdictions.
This provision establishes a dual legal basis structure for marketing communications and personalization profiling: consent where obtained, and legitimate interests where consent has not been separately sought. This means Palantir may send marketing communications without prior consent in contexts where legitimate interests is asserted as the applicable basis, subject to the right to object.
Under this provision, individuals in EEA, UK, and Swiss contexts may receive marketing communications and be subject to personalization profiling without prior consent where Palantir relies on legitimate interests. Individuals have the right to object to this processing by contacting privacy@palantir.com or using the unsubscribe mechanism in communications.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Palantir.