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The policy authorizes use and transfer of Personal Data, including as a business asset, in connection with mergers, acquisitions, divestitures, restructurings, dissolutions, bankruptcy proceedings, or similar transactions.
This analysis describes what Together AI'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 authorizes Personal Data to be transferred to a successor entity in a corporate transaction without requiring individual user consent for that specific transfer, which is a standard but operationally significant commercial term affecting how user data may be handled following a change of corporate control.
Under this provision, Personal Data may be transferred to a third party as part of a merger, acquisition, or similar corporate transaction, including bankruptcy proceedings. The agreement states that Personal Data held about service users is among the assets that may be transferred in such transactions.
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"We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.Excerpt from Together AI's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 regarding lawful basis for processing in corporate transaction contexts, as well as FTC guidance on data transfers in acquisitions, including the FTC's historical enforcement position that acquired companies may not use data in ways that contradict original privacy promises without consent. The CCPA requires disclosure of categories of recipients for transferred Personal Data. (2) GOVERNANCE EXPOSURE: Medium. The provision is standard in commercial privacy policies, but GDPR and FTC enforcement history establish that successor entities cannot use transferred Personal Data in ways that materially depart from the original privacy representations without obtaining fresh consent or providing notice and opt-out opportunity. (3) JURISDICTION FLAGS: EEA, Swiss, and UK users have heightened exposure because GDPR requires a valid legal basis for any new processing by a successor entity; a corporate transaction does not automatically provide legal basis for materially different use of transferred data. California residents retain CCPA rights with respect to transferred data. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers with data processing agreements should assess whether those agreements include provisions addressing data handling in the event of a Together AI change of control, including successor entity obligations. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should monitor for any announced corporate transactions involving Together AI and assess whether successor entity privacy commitments align with the original policy representations.
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This provision authorizes Personal Data to be transferred to a successor entity in a corporate transaction without requiring individual user consent for that specific transfer, which is a standard but operationally significant commercial term affecting how user data may be handled following a change of corporate control.
Under this provision, Personal Data may be transferred to a third party as part of a merger, acquisition, or similar corporate transaction, including bankruptcy proceedings. The agreement states that Personal Data held about service users is among the assets that may be transferred in such transactions.
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