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.
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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...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"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 Walgreens Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly engages the California Consumer Privacy Act as amended by the CPRA, enforced by the California Privacy Protection Agency and the California Attorney General. CPRA requires businesses to provide a 'Do Not Sell or Share My Personal Information' link, honor Global Privacy Control signals, and apply data minimization to shared data categories. The FTC Act may also apply if opt-out mechanisms are not implemented in a manner consistent with representations made. 2. GOVERNANCE EXPOSURE: High. The characterization of advertising data sharing as potentially constituting a sale or sharing under CPRA creates ongoing compliance obligations including opt-out infrastructure, vendor contract requirements, and annual data minimization reviews. Failure to honor opt-out requests or GPC signals is a primary enforcement focus of the California Privacy Protection Agency. 3. JURISDICTION FLAGS: California residents are the primary affected population under CPRA. Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws may impose analogous opt-out rights for targeted advertising, creating multi-state compliance obligations. Non-US users are not addressed in this provision. 4. CONTRACT AND VENDOR IMPLICATIONS: Service provider and contractor agreements with advertising and analytics partners must include data processing limitations consistent with CPRA's service provider definition to avoid those transfers being characterized as sales. Procurement teams should audit whether downstream partners are contractually prohibited from retaining, using, or disclosing shared data beyond the specified purpose. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the technical implementation of the opt-out mechanism, confirm GPC signal recognition is operational, review the list of advertising and analytics partners receiving personal information, and verify that data shared does not include HIPAA-regulated pharmacy data without appropriate authorization.
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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.
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