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

Data Transfer in Mergers and Acquisitions

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Document Record

What it is

The policy states that personal information collected from customers may be disclosed to potential buyers or transferred to acquiring entities in connection with mergers, acquisitions, or the sale of Walgreens stores or assets, and that customer information is treated as a transferred business asset in such transactions.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that customer personal information, including all categories described in the policy, may be disclosed during the evaluation phase of a potential transaction and transferred to a new entity following an acquisition, without requiring separate individual consent at the time of transfer.

Consumer impact (what this means for users)

Under this provision, all categories of personal information Walgreens has collected about a customer, including sensitive personal information and health-related retail purchase data, may be transferred to another entity as a business asset in the event of a merger, acquisition, or asset sale. The policy does not describe a mechanism for consumers to opt out of data transfer in this context.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
As we continue to develop our business, we might sell or buy stores or assets, or engage in mergers, acquisitions or sale of company assets. Personal information may be disclosed in connection with the evaluation of or entry into such transactions or related business arrangements, or in the course of providing transition of services to another entity as permitted by law. In such transactions, customer information generally is one of the transferred business assets. Additionally, in the event that Walgreens or substantially all of its assets are acquired, customer information will likely be one of the transferred assets as is permissible under law.

Excerpt from Walgreens'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 →

Provision details

Document information
Document
Walgreens Privacy Policy
Entity
Walgreens
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015999
Document ID
CA-D-00607
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0f6950919c3da86eab3e4508cb5f4a2245adf341abd12140770ea06252d7325e
Analysis generated
July 9, 2026 09:20 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Walgreens
Document: Walgreens Privacy Policy
Record ID: CA-P-015999
Captured: 2026-07-09 09:20:15 UTC
SHA-256: 0f6950919c3da86e…
URL: https://conductatlas.com/platform/walgreens/walgreens-privacy-policy/provision/CA-P-015999/data-transfer-in-mergers-and-acquisitions/
Accessed: Sept. 21, 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 Walgreens's Data Transfer in Mergers and Acquisitions clause do?

This provision establishes that customer personal information, including all categories described in the policy, may be disclosed during the evaluation phase of a potential transaction and transferred to a new entity following an acquisition, without requiring separate individual consent at the time of transfer.

How does this clause affect you?

Under this provision, all categories of personal information Walgreens has collected about a customer, including sensitive personal information and health-related retail purchase data, may be transferred to another entity as a business asset in the event of a merger, acquisition, or asset sale. The policy does not describe a mechanism for consumers to opt out of data transfer in this …

Is ConductAtlas affiliated with Walgreens?

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