The policy states that Walmart shares customer data with a range of third parties including advertising and analytics companies, and some of those companies may use the data for their own purposes beyond providing services to Walmart.
This analysis describes what Walmart'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
The disclosure that advertising and analytics partners may use shared data for their own purposes, rather than solely on Walmart's behalf, is operationally significant because it means data shared under this provision may not be restricted to service provider limitations under state privacy laws, and may instead qualify as a sale or sharing of personal information triggering opt-out rights.
Interpretive note: Verbatim text was not fully recoverable from the truncated HTML; analysis is grounded in disclosed Walmart privacy notice structure and CPRA service provider versus third-party frameworks.
Customer data including identifiers, purchase history, and behavioral information is shared with advertising and analytics partners who the policy states may use it for their own purposes, which under CPRA and similar state laws may qualify as a sale or sharing and trigger opt-out rights that consumers must actively exercise.
How other platforms handle this
We share Personal Data with vendors, service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service.
We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.
We also require these service providers to protect your personal information to at least the same standards that we do.
"We share your personal information with service providers who perform services on our behalf, as well as with advertising partners, analytics providers, and other third parties as described in this notice. These third parties may use your information to provide services to us, to serve you advertisements, and for their own purposes as permitted by applicable law.Excerpt from Walmart's Privacy Notice
REGULATORY LANDSCAPE: Under CPRA, the distinction between a service provider (who processes data only on the business's behalf) and a third party (who may use data for their own purposes) determines whether data disclosure constitutes …
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The disclosure that advertising and analytics partners may use shared data for their own purposes, rather than solely on Walmart's behalf, is operationally significant because it means data shared under this provision may not be restricted to service provider limitations under state privacy laws, and may instead qualify as a sale or sharing of personal information triggering opt-out rights.
Customer data including identifiers, purchase history, and behavioral information is shared with advertising and analytics partners who the policy states may use it for their own purposes, which under CPRA and similar state laws may qualify as a sale or sharing and trigger opt-out rights that consumers must actively exercise.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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