Smartsheet · Smartsheet Privacy Policy · View original document ↗

Business Transfer and Merger Data Sharing

Low severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity Smartsheet recorded 2 documented changes in the last 30 days.
Start monitoring updates
Monitor governance changes for Smartsheet Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
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.

Recent Activity

This document changed recently

Medium Jun 5, 2026

The updated privacy policy states that only Smartsheet's U.S.-based affiliates participate in the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework. Previously, the policy referenced participation by Smartsheet and its affiliates without geographic qualification. This narrowed scope may affect the data transfer mechanisms available for processing personal data from EU, UK, and Swiss users if non-U.S. affiliates are involved in data handling. The policy does not explicitly describe alternative transfer mechanisms for non-U.S. affiliates.

View change record →

Change history

removed May 21, 2026

Removal of explicit business transfer notice eliminates disclosure about circumstances under which personal data may be transferred to new entities, which affects user rights in M&A scenarios.

View full change record →

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

MetaMask Medium

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.

Ledger Medium

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.

Target Medium

Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.

See all platforms with this clause type →

Monitoring

Smartsheet has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.

Start Monitor free trial Or create a free account →
▸ 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.

Track 1 platform — free Try Monitor free for 14 days

Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.

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: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

Related Analysis

Compliance Governance Intelligence

Need to monitor specific governance provisions?

Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Compliance free trial

Or start with Monitor →

Built from archived source documents, structured governance mappings, and historical version tracking.

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.