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The policy discloses that for users who joined after October 14, 2021, Ro may share email addresses and other customer information with third-party advertising networks for targeted advertising across the internet, and may provide customer information to service providers for cookie-matching to deliver ads on other websites and apps.
This analysis describes what Ro'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 establishes a date-conditioned data sharing practice that may constitute a sale or share of personal information under applicable state privacy laws. The disclosure of email addresses to advertising networks for identity-based cross-site targeting is a material data sharing practice that may require opt-out mechanisms under state consumer privacy law.
Under these terms, if you joined Ro after October 14, 2021, your email address and customer information may be shared with advertising networks and used to identify and target you with ads on other websites and applications. This practice is subject to opt-out via ro.co/do-not-sell/ for residents of applicable states.
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"If you began using the Services after October 14th, 2021, we may also disclose customer information such as your email address with third-party advertising networks that use such information to better target advertising to you regarding Ro products and services, as well as other products and services, as you browse the internet. We sometimes provide our customer information (such as email addresses) to service providers, who may 'match' this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.Excerpt from Ro's Privacy Policy
REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA definitions of sale and sharing of personal information, as well as equivalent definitions in Texas, Colorado, Connecticut, and other state privacy laws. The sharing of email addresses with advertising networks for cross-site targeting is the type of practice that state privacy regulators have identified as requiring opt-out notice. The FTC Act's prohibition on unfair or deceptive practices is also relevant. GOVERNANCE EXPOSURE: High. The disclosure of email addresses and customer identifiers to third-party advertising networks for behavioral targeting across the internet is a practice that regulators in multiple states have scrutinized. The date condition creates a defined class of affected users but does not limit the ongoing scope of this practice. JURISDICTION FLAGS: California, Colorado, Connecticut, Texas, and other listed states with consumer privacy laws create opt-out obligations for this type of data sharing. Nevada's privacy law may also apply. The practice of sharing identifiable customer information with advertising networks may require evaluation under each state's definition of sale or share. CONTRACT AND VENDOR IMPLICATIONS: Advertising network agreements should specify permitted data uses and include data use restrictions consistent with applicable state privacy law. The cookie-matching practice involves additional technical partners whose data practices should be assessed through vendor due diligence. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism at ro.co/do-not-sell/ technically prevents email addresses from being shared with advertising networks when exercised, audit the list of advertising network partners receiving customer data, and assess whether the disclosures in the policy satisfy state-law notice requirements for sale or sharing of personal information.
This provision establishes a date-conditioned data sharing practice that may constitute a sale or share of personal information under applicable state privacy laws. The disclosure of email addresses to advertising networks for identity-based cross-site targeting is a material data sharing practice that may require opt-out mechanisms under state consumer privacy law.
Under these terms, if you joined Ro after October 14, 2021, your email address and customer information may be shared with advertising networks and used to identify and target you with ads on other websites and applications. This practice is subject to opt-out via ro.co/do-not-sell/ for residents of applicable states.
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