Smartsheet · Smartsheet Privacy Policy · View original document ↗

Business Transfer and Merger Data Sharing

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Document Record

What it is

If Smartsheet is sold, merged, or undergoes a major business transaction, your personal data may be transferred to the acquiring company as part of that deal.

This analysis describes what Smartsheet'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

In the event of a corporate transaction, your personal data could be transferred to a new company with different privacy practices, and you may have limited ability to prevent that transfer.

Consumer impact (what this means for users)

Your personal data including contact details, usage history, and account information could be transferred to a new corporate owner if Smartsheet is acquired or merged, potentially subjecting your data to a different company's privacy practices.

How other platforms handle this

Skillshare Medium

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.

Lime Medium

We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...

Oura Medium

We process personal data you provide to Oura to enable third party integrations, services, features, and offerings. For example, with your permission, our Services may integrate with third-party services like Google Health Connect and Apple HealthKit, or those of our partners. Oura takes measures to...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may disclose or transfer your personal data 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 Smartsheet's Smartsheet Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Business transfer data disclosures are standard in US privacy policies and are generally permitted under CCPA as part of an asset sale, subject to requirements that the recipient honor the original privacy commitments. GDPR requires that data transfers in M&A contexts are conducted with appropriate legal basis and that data subjects are notified of material changes in controller identity. The FTC has taken action in cases where acquirers materially changed privacy practices without adequate notice. (2) GOVERNANCE EXPOSURE: Low to Medium. The provision is standard industry language, but enterprise customers should be aware that a Smartsheet acquisition could result in their service data being accessible to a new corporate entity, which may affect their own vendor risk posture and data processing agreement validity. (3) JURISDICTION FLAGS: EU and UK organizations should note that a transfer of controller identity in an M&A context may require GDPR notification obligations. California residents retain CCPA rights against the acquiring entity if it receives their data. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should review whether their DPA with Smartsheet survives a corporate transaction and whether it requires Smartsheet to notify them of ownership changes that affect data processing. Standard enterprise agreements may or may not include such protections. (5) COMPLIANCE CONSIDERATIONS: Legal teams should include change-of-control notification requirements in their Smartsheet service agreements and monitor Smartsheet's corporate status as part of ongoing vendor management.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over data practices in M&A contexts, including cases where an acquirer materially changes privacy commitments made to consumers
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Smartsheet Privacy Policy
Entity
Smartsheet
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-008063
Document ID
CA-D-00712
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
aa3e2b37314e800adf6f92513bffd0a54c2369282b4a03c0788838ef681cf41e
Analysis generated
May 7, 2026 16:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Smartsheet
Document: Smartsheet Privacy Policy
Record ID: CA-P-008063
Captured: 2026-05-07 16:22:45 UTC
SHA-256: aa3e2b37314e800a…
URL: https://conductatlas.com/platform/smartsheet/smartsheet-privacy-policy/business-transfer-and-merger-data-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Smartsheet's Business Transfer and Merger Data Sharing clause do?

In the event of a corporate transaction, your personal data could be transferred to a new company with different privacy practices, and you may have limited ability to prevent that transfer.

How does this clause affect you?

Your personal data including contact details, usage history, and account information could be transferred to a new corporate owner if Smartsheet is acquired or merged, potentially subjecting your data to a different company's privacy practices.

Is ConductAtlas affiliated with Smartsheet?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Smartsheet.