The policy authorizes transfer of user data to a successor or affiliate entity in connection with a sale, negotiation of a sale, or acquisition of Snap Inc.'s business. The provision applies to negotiations as well as completed transactions.
This analysis describes what Snapchat'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 that user data may be transferred to a potential acquirer even during the negotiation phase of a transaction, before any sale is finalized. The absence of stated conditions on the acquirer's data use obligations or user notification mechanisms is standard for acquisition clauses but may be relevant for compliance teams assessing data continuity risk.
Under this clause, user data collected under this policy may be transferred to a new owner or affiliate if Snap is sold or enters acquisition negotiations, potentially resulting in the data being processed under a different entity's privacy practices after the transaction. The policy does not specify user notification procedures specific to a transaction event.
Cross-platform context
See how other platforms handle Data Sharing in Merger or Acquisition and similar clauses.
Compare across platforms →"For the purposes of a Merger or Acquisition. If we were to sell or negotiate to sell our business to a buyer or possible buyer, we may transfer your information to a successor or affiliate as part of that transaction.Excerpt from Snapchat's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR requires that any change in data controller resulting from a merger or acquisition be documented, and that users be informed of material changes to data processing.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision establishes that user data may be transferred to a potential acquirer even during the negotiation phase of a transaction, before any sale is finalized. The absence of stated conditions on the acquirer's data use obligations or user notification mechanisms is standard for acquisition clauses but may be relevant for compliance teams assessing data continuity risk.
Under this clause, user data collected under this policy may be transferred to a new owner or affiliate if Snap is sold or enters acquisition negotiations, potentially resulting in the data being processed under a different entity's privacy practices after the transaction. The policy does not specify user notification procedures specific to a transaction event.
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