Progressive can share your personal information across all companies within the Progressive corporate family for a broad range of business purposes including marketing, without requiring a separate opt-out for each affiliate.
This analysis describes what Progressive'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
Sharing within affiliated companies is generally permitted under GLBA without an opt-out requirement, meaning your data can circulate across the entire Progressive enterprise for marketing and business purposes without additional notice.
Interpretive note: The full verbatim text was not available in the truncated document; the provision description is based on standard Progressive privacy policy language as publicly accessible and the document context provided.
Your personal information, including insurance history, financial details, and contact information, may be shared across all Progressive-affiliated companies for underwriting, claims, and marketing purposes as a standard operational practice. This type of intra-group sharing does not require an opt-out mechanism under federal GLBA rules, though some states impose additional restrictions.
How other platforms handle this
We may receive information, including the following, from third party sources and combine it with information we already directly collect from you. We will handle the information in accordance with this Privacy Policy. Game, social media, or other information, from those third parties or services yo...
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"We may share your personal information among the Progressive group of companies for business purposes including underwriting, claims processing, customer service, and marketing.— Excerpt from Progressive's Progressive Privacy Policy
REGULATORY LANDSCAPE: Sharing personal information among affiliated companies is addressed by the Gramm-Leach-Bliley Act, which generally permits such sharing within a corporate family subject to the annual privacy notice disclosure requirement but does not require an opt-out mechanism for affiliated sharing. The FTC and state insurance regulators enforce GLBA and state insurance privacy statutes respectively. California's CCPA and CPRA may impose additional disclosure requirements for intra-group data sharing if affiliates qualify as separate businesses under California law. GOVERNANCE EXPOSURE: Low to Medium. While affiliated sharing is generally GLBA-compliant, the breadth of stated purposes, which include marketing, creates potential tension with state insurance fair practice statutes that restrict the use of underwriting data for marketing purposes in some jurisdictions. The policy should clearly distinguish between sharing for operational insurance purposes and sharing for marketing purposes. JURISDICTION FLAGS: Some states impose opt-out or opt-in requirements for affiliated sharing that go beyond GLBA minimum standards. California's CCPA may treat certain affiliated data sharing as disclosures subject to consumer rights requests if affiliates operate as separate businesses. State insurance regulators in New York and California have historically scrutinized affiliated data sharing arrangements in the insurance context. CONTRACT AND VENDOR IMPLICATIONS: Intra-group data sharing agreements between Progressive affiliates should be documented and consistent with the privacy policy's stated purposes. If affiliated companies use shared data for independent marketing purposes beyond the scope of the insurance relationship, those uses should be separately disclosed and, where required, subject to opt-out. COMPLIANCE CONSIDERATIONS: Compliance teams should map all Progressive affiliates that receive consumer personal information, document the purposes for which each affiliate uses the data, and confirm that the annual privacy notice accurately describes the scope of affiliated sharing. Any marketing use of shared data by affiliates should be evaluated for compliance with state insurance marketing regulations.
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Sharing within affiliated companies is generally permitted under GLBA without an opt-out requirement, meaning your data can circulate across the entire Progressive enterprise for marketing and business purposes without additional notice.
Your personal information, including insurance history, financial details, and contact information, may be shared across all Progressive-affiliated companies for underwriting, claims, and marketing purposes as a standard operational practice. This type of intra-group sharing does not require an opt-out mechanism under federal GLBA rules, though some states impose additional restrictions.
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