Non-Affiliated Third-Party Marketing Sharing

What it is

Progressive may share your personal information with outside companies for joint marketing, but you have the right to opt out of this sharing by contacting Progressive.

Why it matters (compliance & governance perspective)

Your name, contact details, and potentially insurance-related information could be passed to outside marketing partners unless you affirmatively opt out, which many consumers may not know to do.

Consumer impact (what this means for users)

Unless you opt out, Progressive may share your personal information with non-affiliated third parties for marketing purposes, which could result in unsolicited contact from companies you did not choose to engage. Exercising the opt-out right prevents this sharing going forward but may not affect data already disclosed.

What you can do

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Sharing personal financial information with non-affiliated third parties for joint marketing directly implicates the Gramm-Leach-Bliley Act's privacy provisions, which require a clear opt-out mechanism and an annual privacy notice. The FTC enforces GLBA privacy provisions for non-bank financial institutions including insurers in some contexts, while state insurance commissioners enforce state-level analogues. California's CCPA and CPRA grant residents additional rights to opt out of the sale or sharing of personal information for cross-context behavioral advertising. GOVERNANCE EXPOSURE: Medium. GLBA requires that the opt-out notice be reasonably accessible and that consumers have a reasonable period to opt out before sharing begins. If the policy does not clearly specify the categories of non-affiliated companies receiving data or the types of joint marketing involved, regulators may view the disclosure as insufficiently specific under GLBA or CCPA transparency requirements. JURISDICTION FLAGS: California residents have CCPA rights to opt out of sale or sharing of personal information and to receive a list of categories of third parties with whom data has been shared. Several other states including Virginia, Colorado, and Connecticut have enacted comprehensive privacy laws with similar opt-out rights that may apply depending on residency. CONTRACT AND VENDOR IMPLICATIONS: Joint marketing agreements with non-affiliated companies should include contractual restrictions on secondary use of shared data, consistent with GLBA safe harbor requirements. Legal teams should confirm that joint marketing partners are identified and that data sharing agreements are current and compliant with applicable state privacy laws. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the opt-out mechanism to confirm it is functional, prominent, and documented. A record of which non-affiliated companies have received customer data for joint marketing purposes should be maintained for regulatory inquiry response. Annual privacy notice delivery obligations under GLBA should be confirmed for all applicable customer segments.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Snapshot Telematics Data Collection high
• Collection of Sensitive Personal Identifiers medium
• California CCPA Consumer Rights medium
• Website Behavioral Tracking and Cookies medium
• Information Sharing with Affiliated Companies low
• Email Address Collection and Marketing Use low

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