Provision record
Starbucks · Starbucks Privacy Policy · View original document ↗

Advertising Data Sharing Characterized as Potential Sale

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Document Record

What it is

The notice discloses that sharing of identifiers, device and network activity, transaction information, and inferences with advertising partners may qualify as a sale or sharing of personal information for targeted advertising under applicable privacy law, even though no monetary compensation is received.

This analysis describes what Starbucks'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)

This provision establishes that Starbucks' advertising data flows may trigger opt-out rights under CCPA and CPRA, requiring the company to maintain functional opt-out mechanisms and honor opt-out preference signals from browsers, with operational implications for advertising vendor contracts and consent infrastructure.

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, certain categories of personal information including identifiers, browsing and device activity, transaction history, and behavioral inferences are shared with advertising partners in a manner the notice characterizes as a potential sale or sharing under applicable privacy law. You can opt out of this sharing via the Cookie Preferences link on the Starbucks website, the Do Not Sell or Share My Personal Information link, or by submitting a request through the designated online form.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to the Starbucks website, scroll to the bottom of the page, and click the Cookie Preferences link or the Do Not Sell or Share My Personal Information link to submit an opt-out request. Repeat this step for each browser and device you use, and repeat after clearing cookies.

Cross-platform context

See how other platforms handle Advertising Data Sharing Characterized as Potential Sale and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Although we do not sell your personal information for money, our sharing of your personal information with some advertising partners (including certain identifiers, internet or other network or device activity information, transaction information, and inferences about your use of Starbucks Services) may be deemed a 'sale' or 'sharing' for targeted advertising purposes under applicable privacy laws.

Excerpt from Starbucks's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
Starbucks Privacy Policy
Entity
Starbucks
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
July 9, 2026
Record ID
CA-P-016041
Document ID
CA-D-00625
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d5e55caca30087576ff29e8885b4a497cdbdb144634f613e23bb0595052cacad
Analysis generated
May 7, 2026 05:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Starbucks
Document: Starbucks Privacy Policy
Record ID: CA-P-016041
Captured: 2026-05-07 05:55:31 UTC
SHA-256: d5e55caca3008757…
URL: https://conductatlas.com/platform/starbucks/starbucks-privacy-policy/provision/CA-P-016041/advertising-data-sharing-characterized-as-potential-sale/
Accessed: Aug. 11, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Starbucks's Advertising Data Sharing Characterized as Potential Sale clause do?

This provision establishes that Starbucks' advertising data flows may trigger opt-out rights under CCPA and CPRA, requiring the company to maintain functional opt-out mechanisms and honor opt-out preference signals from browsers, with operational implications for advertising vendor contracts and consent infrastructure.

How does this clause affect you?

Under this clause, certain categories of personal information including identifiers, browsing and device activity, transaction history, and behavioral inferences are shared with advertising partners in a manner the notice characterizes as a potential sale or sharing under applicable privacy law. You can opt out of this sharing via the Cookie Preferences link on the Starbucks website, the Do Not Sell …

Is ConductAtlas affiliated with Starbucks?

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