The notice references a consent management platform (Ketch, as identified in the page source) for managing cookie and tracking technology preferences, authorizing collection of device identifiers, browsing activity, and related data subject to user consent or opt-out choices.
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
This provision governs the collection of device identifiers and browsing activity through cookies and tracking technologies, determining which data flows are subject to prior consent and which are managed through opt-out, with direct implications for advertising and analytics partner data sharing.
Interpretive note: The specific categories of cookies in use and the precise scope of consent versus opt-out mechanisms are described in linked sub-notices and the consent management platform interface rather than the main notice text.
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 →Specific cookie management instructions and functionality implications were removed and replaced with a generic reference to layered notices.
View full change record →The agreement establishes that cookie and tracking technology preferences can be managed through the consent tool available on the Smartsheet website, and that certain advertising and analytics data collection is subject to user consent or opt-out choices as described in the notice.
How other platforms handle this
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"The Smartsheet Privacy Notice ("Privacy Notice") consists of this page and the specific notices which describe how we collect, use, and share personal data and explain your related rights and choices.— Excerpt from Smartsheet's Smartsheet Privacy Policy
1. REGULATORY LANDSCAPE: Cookie and tracking technology consent implicates the EU ePrivacy Directive (Cookie Law), GDPR consent requirements for non-essential cookies, UK PECR (Privacy and Electronic Communications Regulations), and CCPA and CPRA provisions on the use of automated data collection technologies. The relevant enforcement authorities include EU data protection authorities, the UK ICO, and the California Privacy Protection Agency. 2. GOVERNANCE EXPOSURE: Medium. The implementation of a third-party consent management platform (Ketch) introduces a vendor dependency for compliance with cookie consent obligations. Compliance teams should verify that the consent management platform is configured to meet applicable legal standards in each jurisdiction, including that consent is freely given, specific, informed, and unambiguous for EU and UK users. 3. JURISDICTION FLAGS: EU and EEA users require prior consent for non-essential cookies under the ePrivacy Directive. UK users are subject to PECR. California users may opt out of the sale or sharing of personal information collected through tracking technologies under CCPA and CPRA. Other US state privacy laws may impose similar opt-out requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: The use of Ketch as a consent management platform should be assessed in vendor due diligence to confirm that it meets applicable legal standards, that data flows through the platform are documented, and that Ketch's own data practices are compatible with Smartsheet's privacy obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should conduct periodic audits of the consent management platform configuration to confirm that consent records are captured and retained, that opt-out signals (including Global Privacy Control where applicable) are honored, and that the categories of cookies and tracking technologies in use are consistent with those disclosed in the notice.
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This provision governs the collection of device identifiers and browsing activity through cookies and tracking technologies, determining which data flows are subject to prior consent and which are managed through opt-out, with direct implications for advertising and analytics partner data sharing.
The agreement establishes that cookie and tracking technology preferences can be managed through the consent tool available on the Smartsheet website, and that certain advertising and analytics data collection is subject to user consent or opt-out choices as described in the notice.
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