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The policy states that third-party advertising networks place cookies on users' devices to collect data and build behavioral profiles for targeted advertising on Walgreens' website and third-party websites, and that some of these networks participate in opt-out programs operated by the Digital Advertising Alliance and Network Advertising Initiative.
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 advertising networks to build behavioral profiles from user data collected across Walgreens and unaffiliated websites, and discloses that opting out of interest-based advertising does not stop data collection for analytics and fraud prevention purposes.
Under this provision, third-party advertising networks operating on Walgreens' website may collect user data across sessions and websites to build behavioral profiles for targeted advertising. The policy states that opting out of interest-based advertising stops ad personalization but not the continued collection of user data for other permitted purposes including analytics.
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"We may also use third-party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioral profiles by these companies to deliver targeted advertisements on our website and unaffiliated websites. [...] These third-party advertisers may be participants in the Digital Advertising Alliance and/or the Network Advertising Initiative, which allow users to opt out of ad targeting from participating companies.Excerpt from Walgreens's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages CPRA's sale and sharing opt-out requirements, as disclosures to advertising networks for behavioral profiling may constitute sharing under California law. The FTC Act applies to cross-context behavioral advertising practices. The FTC's 2022 commercial surveillance report and subsequent policy actions are relevant regulatory context for third-party behavioral profiling, though enforcement outcomes should not be assumed. EU GDPR and ePrivacy Directive are not directly applicable to US-based users but may be relevant if Walgreens' digital services are accessed by EU residents. 2. GOVERNANCE EXPOSURE: Medium. The policy's disclosure that opting out of interest-based advertising does not stop data collection for analytics is operationally significant because it limits the practical effect of the opt-out mechanism for users who expect a full data collection stop. This distinction should be clearly communicated at the point of opt-out. 3. JURISDICTION FLAGS: California residents have CPRA opt-out rights applicable to sharing with advertising networks that may constitute a sale or sharing of personal information. Residents of the nineteen additional states listed in the policy may have analogous rights. The policy's reference to opt-out preference signal recognition at a browser level is directly relevant to California's Global Privacy Control requirement. 4. CONTRACT AND VENDOR IMPLICATIONS: Agreements with third-party advertising networks should specify data use limitations consistent with the policy's disclosures and applicable state opt-out requirements. If advertising networks receive precise geolocation or purchase history data, those disclosures should be assessed against CPRA's Sensitive Personal Information requirements. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out preference signal recognition process described in the policy is technically implemented and honors Global Privacy Control signals in California-compliant fashion. The policy's statement that data collection continues after an advertising opt-out should be reviewed for consistency with applicable state law requirements governing the scope of opt-out rights.
This provision authorizes third-party advertising networks to build behavioral profiles from user data collected across Walgreens and unaffiliated websites, and discloses that opting out of interest-based advertising does not stop data collection for analytics and fraud prevention purposes.
Under this provision, third-party advertising networks operating on Walgreens' website may collect user data across sessions and websites to build behavioral profiles for targeted advertising. The policy states that opting out of interest-based advertising stops ad personalization but not the continued collection of user data for other permitted purposes including analytics.
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