NBCUniversal may use sensitive personal information such as your precise location to show you targeted advertising, to the extent this is permitted by applicable law.
This analysis describes what Peacock'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
The clause establishes the operational scope of data usage for advertising functions, specifying that sensitive categories of personal information—particularly geolocation data—may be processed for targeting and analytics purposes across both first-party and third-party advertising channels.
Interpretive note: The permissibility of using sensitive personal information for targeted advertising varies by jurisdiction, and the policy's 'as allowable by law' qualifier creates a compliance obligation whose scope depends on the user's location and applicable state or national law.
Your sensitive personal information, including precise geolocation data, may be used to target you with advertising both on NBCUniversal services and on other sites, subject only to what applicable law permits in your jurisdiction.
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"Sensitive Data We may use certain sensitive personal information as allowable by law for purposes including analytics and to enable marketing to you and the delivery of targeted advertising on the NBCUniversal Services or other sites, such displaying an ad relevant to your precise location data.— Excerpt from Peacock's Peacock Privacy Policy
REGULATORY LANDSCAPE: CCPA/CPRA creates a specific right to limit the use and disclosure of sensitive personal information, which includes precise geolocation, health data, and biometric identifiers, and does not permit their use for inferring characteristics or targeted advertising without user authorization. The policy's use of 'as allowable by law' may be inconsistent with CPRA's requirement that sensitive data not be used for targeted advertising unless the consumer opts in or fails to exercise the right to limit. The FTC has identified sensitive data misuse for advertising as a priority enforcement area. GOVERNANCE EXPOSURE: High. The assertion that sensitive personal information may be used for targeted advertising 'as allowable by law' creates a jurisdiction-dependent compliance obligation that requires precise legal analysis in each applicable state. Under CPRA, this may require an opt-in rather than an opt-out model for California residents. JURISDICTION FLAGS: California's CPRA provides a right to limit use of sensitive personal information that is distinct from the opt-out of sale or sharing, and NBCUniversal must provide a separate mechanism for this right. Colorado, Connecticut, and Virginia similarly provide rights regarding sensitive data. EU and UK users benefit from GDPR Article 9's prohibition on processing special category data for advertising without explicit consent. CONTRACT AND VENDOR IMPLICATIONS: Advertising partners receiving sensitive personal information from NBCUniversal should confirm that their own processing of this data is consistent with applicable law and that their agreements with NBCUniversal specify permissible use cases. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the 'Limit the Use of My Sensitive Personal Information' right required by CPRA is separately implemented and whether the user-facing mechanism distinguishes this right from the general opt-out of sale or sharing. A jurisdiction-by-jurisdiction analysis of permissible sensitive data use for advertising is warranted given the breadth of the policy's assertion.
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The clause establishes the operational scope of data usage for advertising functions, specifying that sensitive categories of personal information—particularly geolocation data—may be processed for targeting and analytics purposes across both first-party and third-party advertising channels.
Your sensitive personal information, including precise geolocation data, may be used to target you with advertising both on NBCUniversal services and on other sites, subject only to what applicable law permits in your jurisdiction.
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