If Pinterest is sold, merged, or goes through bankruptcy, your personal data may be transferred to the new owner as part of that deal.
This analysis describes what Pinterest'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 states that user personal data is an asset that may be transferred to a new entity in a corporate transaction, and the receiving party may operate under different data practices than the current policy describes.
The policy states that your personal data, including identifiers, behavioral data, and financial information, may be transferred to a third party in the event of a merger, acquisition, or asset sale, with notice of any resulting privacy policy change provided but no stated right to object to or prevent the transfer.
How other platforms handle this
In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.
We may access, preserve, and share information with regulators, law enforcement, or others if we believe it is reasonably necessary to: detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others, including as part of investigations; and prevent death or imminen...
Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission's adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of ...
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"If Pinterest is involved in a merger, acquisition, bankruptcy, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any change in applicable privacy policy.— Excerpt from Pinterest's Pinterest Privacy Policy
(1) REGULATORY LANDSCAPE: Under GDPR, a business transfer involving personal data of EEA residents requires a valid legal basis for the onward transfer and may require notification to relevant Data Protection Authorities. Under CCPA, transfer of personal information in a merger or acquisition is not classified as a sale, but the successor entity must honor existing opt-out requests. The FTC has taken enforcement action in cases where successor entities materially changed privacy practices following asset transfers. (2) GOVERNANCE EXPOSURE: Medium. The policy commits to notifying users of privacy policy changes following a business transfer but does not specify a timeline or grant users a right to withdraw data prior to transfer. This may create tension with GDPR rights and with FTC guidance on material privacy policy changes. (3) JURISDICTION FLAGS: EEA users may have GDPR rights to object to processing by a successor entity if the legal basis changes. California users retain CCPA rights against the successor entity. Heightened exposure exists where the successor entity is located outside jurisdictions with adequate data protection. (4) CONTRACT AND VENDOR IMPLICATIONS: In M&A due diligence, acquiring entities should assess the scope and sensitivity of Pinterest's personal data assets, existing regulatory commitments, and open data subject requests. Data representations and warranties in acquisition agreements should address regulatory compliance and pending enforcement matters. (5) COMPLIANCE CONSIDERATIONS: Compliance teams involved in any future transaction should evaluate GDPR notification obligations, assess whether a Transfer Impact Assessment is needed for cross-border data transfers to a successor, and ensure data subject rights requests in flight at the time of transfer are completed or transferred with documented accountability.
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This provision states that user personal data is an asset that may be transferred to a new entity in a corporate transaction, and the receiving party may operate under different data practices than the current policy describes.
The policy states that your personal data, including identifiers, behavioral data, and financial information, may be transferred to a third party in the event of a merger, acquisition, or asset sale, with notice of any resulting privacy policy change provided but no stated right to object to or prevent the transfer.
ConductAtlas has identified this type of provision across 5 platforms. See the full comparison.
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