If Pinecone is sold, merged, or goes through bankruptcy proceedings, your personal information may be transferred to a new owner or become subject to legal proceedings, potentially with limited control over how it is used.
This analysis describes what Pinecone'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 authorizes disclosure of personal information to potential and actual acquirers, and separately acknowledges that in insolvency proceedings Pinecone may not be able to control how personal data is treated, which creates uncertainty about downstream data handling.
Personal information collected by Pinecone may be transferred to a new company in a merger or acquisition, and in insolvency scenarios the policy states Pinecone may not be able to control subsequent use of that data.
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"We may disclose personal information to a potential acquirer, merger partner, or other successor entity in connection with a contemplated or actual sale, merger, acquisition, or other transaction involving the transfer of some or all of our business assets. In the event of a bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.— Excerpt from Pinecone's Pinecone Privacy Policy
REGULATORY LANDSCAPE: Under GDPR, the transfer of personal data in the context of a corporate transaction requires a lawful basis and, for transfers outside the EEA, appropriate safeguards. CPRA requires that acquirers receiving personal data honor the original privacy commitments made to consumers or obtain renewed consent. The FTC has taken action in connection with asset sales that involve changes to privacy representations. Relevant enforcement authorities include EU supervisory authorities, the California Privacy Protection Agency, and the FTC. GOVERNANCE EXPOSURE: Medium. The insolvency carve-out, which states Pinecone may not be able to control how personal data is treated in bankruptcy or reorganization, is operationally significant because it acknowledges a scenario in which privacy commitments may not be honored. The clause authorizing disclosure to potential acquirers (as opposed to completed transactions) also raises questions about how personal data is protected during due diligence processes. JURISDICTION FLAGS: EU and EEA users face heightened exposure if personal data is transferred to a non-EEA acquirer without appropriate GDPR transfer safeguards. California residents should note that CPRA requires acquirers to comply with existing privacy commitments. The insolvency scenario is jurisdiction-dependent and may engage bankruptcy court orders that override contractual privacy commitments. CONTRACT AND VENDOR IMPLICATIONS: M&A due diligence teams reviewing Pinecone as a target or integration partner should assess the scope of personal data held, applicable transfer restrictions, and the data processing agreements in place. The insolvency carve-out should be noted in risk assessments for enterprise procurement. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether existing data subject notices adequately disclose the corporate transaction transfer scenario, and whether GDPR or CPRA require updated notices or consent in the event of a completed acquisition. Data processing agreements with Pinecone should address change of control scenarios.
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This provision authorizes disclosure of personal information to potential and actual acquirers, and separately acknowledges that in insolvency proceedings Pinecone may not be able to control how personal data is treated, which creates uncertainty about downstream data handling.
Personal information collected by Pinecone may be transferred to a new company in a merger or acquisition, and in insolvency scenarios the policy states Pinecone may not be able to control subsequent use of that data.
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