The policy reserves the right to share or transfer user personal data to acquiring entities or counterparties during or in connection with mergers, asset sales, financing transactions, or acquisitions involving RunPod.
This analysis describes what RunPod'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 permits transfer of user personal data to third parties as part of corporate transactions, including during the negotiation phase prior to transaction completion, which may occur without direct user notification depending on the transaction structure.
This new provision addresses data transfer during M&A activity, clarifying user data rights during corporate restructuring events.
View full change record →Under this clause, personal data including account, billing, and usage information may be transferred to a successor entity or transaction counterparty in connection with a corporate sale, merger, or financing event. The policy does not specify whether users will receive advance notice of such transfers or have the ability to request deletion prior to transfer.
How other platforms handle this
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal data may be transferred to a successor entity or third party as part of that transaction.
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.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.— Excerpt from RunPod's RunPod Privacy Policy
1) REGULATORY LANDSCAPE: Business transfer data provisions engage GDPR Article 6 legitimate interest analysis and may require a new lawful basis assessment if the acquiring entity's processing purposes differ materially from RunPod's. CCPA Section 1798.140 treats business transfer recipients as service providers only if they agree to the same data restrictions, otherwise the transfer may constitute a sale. The FTC has scrutinized data transfer provisions in acquisition contexts. 2) GOVERNANCE EXPOSURE: Medium. The provision permits transfers during negotiation phases, which creates a disclosure risk before a transaction is finalized and may expose personal data to parties who do not ultimately acquire the business. 3) JURISDICTION FLAGS: EU/EEA users may have heightened rights in the context of a change of controller resulting from a corporate transaction, including the right to be informed of the new controller's identity. California residents retain CCPA rights against successor entities. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers with data processing agreements should verify whether those agreements include notification obligations triggered by a change of control at RunPod, and whether successor entity obligations are addressed. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether RunPod's transaction transfer language is consistent with applicable GDPR legitimate interest requirements and whether the policy adequately discloses the conditions under which user notification would occur.
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This provision permits transfer of user personal data to third parties as part of corporate transactions, including during the negotiation phase prior to transaction completion, which may occur without direct user notification depending on the transaction structure.
Under this clause, personal data including account, billing, and usage information may be transferred to a successor entity or transaction counterparty in connection with a corporate sale, merger, or financing event. The policy does not specify whether users will receive advance notice of such transfers or have the ability to request deletion prior to transfer.
ConductAtlas has identified this type of provision across 23 platforms. See the full comparison.
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