The policy authorizes sharing of personal information with advertising, analytics, and social media partners for targeted advertising and campaign measurement, and states these partners use tracking technologies including cookies and pixel tags on Walgreens services.
This analysis describes what Walgreens'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 third-party tracking technology deployment on Walgreens platforms, enabling advertising and analytics partners to independently collect device identifiers, browsing activity, and interaction data. The scope of data accessible to third-party pixels and cookies deployed on health-related pages creates specific regulatory exposure under state health data laws and FTC guidance.
Interpretive note: The specific pages on which third-party tracking technologies are deployed, and whether any operate in HIPAA-regulated contexts, cannot be determined from policy text alone.
The policy expands to include analytics and social media partners, and refocuses tracking from 'online activities over time and across different websites' to 'interactions with our services.'
View full change record →Under this provision, advertising and analytics partners may collect device identifiers, browsing activity, and interaction data through cookies and pixel tags deployed on Walgreens websites and apps, including pages related to health and pharmacy services. This data sharing may be subject to opt-out rights under CCPA/CPRA.
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If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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"We share personal information with third-party advertising, analytics, and social media partners to deliver targeted advertisements and measure the effectiveness of our marketing campaigns. These partners may use cookies, pixel tags, and similar technologies to collect information about your interactions with our services.— Excerpt from Walgreens's Walgreens Privacy Policy
1. REGULATORY LANDSCAPE: Third-party pixel and cookie deployment on health-related web pages has been the subject of FTC enforcement actions and HHS guidance regarding HIPAA applicability to tracking technologies. The FTC Act applies to deceptive or unfair practices involving third-party data collection. CCPA/CPRA governs the sharing of personal information with advertising and analytics partners. State health data laws in Washington and Nevada may apply to health-adjacent browsing data captured by third-party trackers. 2. GOVERNANCE EXPOSURE: High. HHS issued guidance in 2022 and subsequent clarifications addressing the use of third-party tracking technologies on HIPAA-covered entity websites, particularly where the pixels may capture IP addresses or health-related URL parameters in combination. Deploying advertising pixels on pharmacy or health-related pages creates potential HIPAA exposure if captured data constitutes PHI. 3. JURISDICTION FLAGS: California CPRA creates opt-out obligations for data shared with advertising partners. Washington My Health MY Data Act may apply to health data captured by third-party trackers on health-related pages. FTC enforcement regarding pixel-based data sharing on healthcare websites is an active area. 4. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with advertising and analytics vendors should specify prohibited data uses, particularly regarding health-related data captured on pharmacy or health product pages. Pixel placement audits should confirm that tracking technologies are not deployed on pages where HIPAA-regulated interactions occur without appropriate authorization. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a pixel and tag audit to identify all third-party tracking technologies deployed across Walgreens digital properties, assess whether any operate on HIPAA-relevant pages, review data processing agreements for advertising and analytics partners, and evaluate consent mechanisms for cookie and tracker deployment in applicable jurisdictions.
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This provision authorizes third-party tracking technology deployment on Walgreens platforms, enabling advertising and analytics partners to independently collect device identifiers, browsing activity, and interaction data. The scope of data accessible to third-party pixels and cookies deployed on health-related pages creates specific regulatory exposure under state health data laws and FTC guidance.
Under this provision, advertising and analytics partners may collect device identifiers, browsing activity, and interaction data through cookies and pixel tags deployed on Walgreens websites and apps, including pages related to health and pharmacy services. This data sharing may be subject to opt-out rights under CCPA/CPRA.
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