The policy discloses that Walgreens shares personal information with advertising partners in ways that may qualify as a sale or sharing for cross-context behavioral advertising under California law, and states that California residents may opt out of this sharing.
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 triggers opt-out rights under CCPA/CPRA for California residents and requires Walgreens to provide a clear and accessible opt-out mechanism, including recognition of the Global Privacy Control signal. The provision also implicates CPRA's annual data minimization obligations for data shared with advertising partners.
Interpretive note: The exact scope of data categories shared for advertising purposes and the technical implementation of opt-out mechanisms cannot be fully assessed from the policy text alone; operational verification is required.
This provision explicitly acknowledges that data sharing for cross-context behavioral advertising constitutes a 'sale' or 'sharing' under California law, providing clarity on regulatory classification that was previously indirect.
View full change record →Under this provision, personal information including browsing activity, purchase history, and device identifiers may be shared with advertising partners for targeted advertising purposes. California residents are entitled under CPRA to opt out of this sharing through the mechanisms described in the policy.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you...
Access information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic information transferred to another party.
"We may share your personal information with third parties for cross-context behavioral advertising, which may be considered a 'sale' or 'sharing' under California law. California residents have the right to opt out of the sale or sharing of their personal information.Excerpt from Walgreens's Privacy Policy
1.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision triggers opt-out rights under CCPA/CPRA for California residents and requires Walgreens to provide a clear and accessible opt-out mechanism, including recognition of the Global Privacy Control signal. The provision also implicates CPRA's annual data minimization obligations for data shared with advertising partners.
Under this provision, personal information including browsing activity, purchase history, and device identifiers may be shared with advertising partners for targeted advertising purposes. California residents are entitled under CPRA to opt out of this sharing through the mechanisms described in the policy.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Walgreens.