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The policy states that Threads collects device identifiers, operating system information, device attributes, device signals, network and connection data, cookie data, and behavioral signals from all connected devices used to access the platform, and that this information is combined across devices.
This analysis describes what Threads'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 Meta collects a broad set of device-level and network-level identifiers and signals from Threads users across all devices, and combines this data across devices. Cross-device identity linking enables persistent tracking of user behavior across sessions, devices, and contexts beyond the Threads application itself.
Under this clause, Threads collects identifiers, device attributes, network signals, cookie data, and behavioral data from every device used to access the platform, and combines this data across devices to build a cross-device user profile. This cross-device combination is used for advertising and personalization purposes as described elsewhere in the policy.
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"We collect information about the computers, phones, connected TVs and other web-connected devices you use that integrate with our products, and we combine this information across different devices you use. Information we obtain from these devices includes: device attributes, device operations, identifiers, device signals, data from device settings, network and connections, and cookie data.Excerpt from Threads's Privacy Policy
1. REGULATORY LANDSCAPE: The collection of device identifiers, cookie data, and cross-device tracking signals engages the EU's ePrivacy Directive (cookie consent requirements) as well as GDPR's requirements for a lawful basis for processing. In the US, the FTC has issued guidance on cross-device tracking practices, and several state privacy laws (CCPA/CPRA, Virginia VCDPA, Colorado CPA) include device identifiers within the definition of personal information and may require disclosure of cross-device tracking in privacy notices. 2. GOVERNANCE EXPOSURE: Medium. Cross-device tracking and identity linking is a standard practice among large advertising-supported platforms; however, the breadth of device signals collected and the cross-device combination described in this provision creates a comprehensive behavioral profile that may raise data minimization concerns under GDPR and heightened scrutiny under state sensitive data frameworks where precise location or health-related inferences are possible. 3. JURISDICTION FLAGS: EU/EEA users are protected by both GDPR and the ePrivacy Directive, which requires consent for non-essential cookie placement and device fingerprinting in many member states. California's CPRA includes device identifiers and IP addresses within the definition of personal information, and cross-device tracking data may fall within categories requiring enhanced disclosure. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying the Meta Pixel or similar tracking tools that send device and behavioral data to Meta should assess whether their consent mechanisms cover the cross-device combination described in this provision, and whether their privacy notices accurately describe the scope of device data collected. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit cookie consent mechanisms to confirm they cover the device signals and cross-device tracking described. Data flow maps should reflect the collection of device identifiers and cross-device combination as part of the Threads data graph.
Regulatory citations, enforcement risk, and due diligence action items.
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This provision establishes that Meta collects a broad set of device-level and network-level identifiers and signals from Threads users across all devices, and combines this data across devices. Cross-device identity linking enables persistent tracking of user behavior across sessions, devices, and contexts beyond the Threads application itself.
Under this clause, Threads collects identifiers, device attributes, network signals, cookie data, and behavioral data from every device used to access the platform, and combines this data across devices to build a cross-device user profile. This cross-device combination is used for advertising and personalization purposes as described elsewhere in the policy.
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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