Walmart states it shares customer personal information with co-branded credit card issuers and other financial partners for joint financial products, and those partners' own privacy notices govern how they use the shared data.
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 policy states that data shared with financial partners is governed by those partners' separate privacy notices, meaning consumers interacting with Walmart co-branded financial products should review both Walmart's notice and the applicable financial institution's privacy disclosures to understand the full scope of data use.
Interpretive note: Whether financial partner transfers constitute third-party sales or sharing under CPRA versus service provider relationships requires a case-by-case contractual analysis not resolvable from the public notice text alone.
The policy states that Walmart shares customer identifiers, purchase history, and financial information with co-branded credit card issuers and financial service partners, and that those partners maintain their own independent privacy notices that govern their use of the shared data, creating a separate data processing relationship outside Walmart's direct control.
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"We may share your personal information with financial institutions, co-branded credit card partners, and other financial service providers in connection with financial products or services offered in partnership with Walmart, such as co-branded credit cards or financing programs. Such sharing is subject to those partners' privacy notices and applicable law.Excerpt from Walmart's Privacy Policy
1) REGULATORY LANDSCAPE: Sharing personal information with financial institutions in connection with co-branded credit products may implicate the Gramm-Leach-Bliley Act (GLBA), which governs financial institution privacy notices and opt-out rights for non-affiliated third-party data sharing.
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The policy states that data shared with financial partners is governed by those partners' separate privacy notices, meaning consumers interacting with Walmart co-branded financial products should review both Walmart's notice and the applicable financial institution's privacy disclosures to understand the full scope of data use.
The policy states that Walmart shares customer identifiers, purchase history, and financial information with co-branded credit card issuers and financial service partners, and that those partners maintain their own independent privacy notices that govern their use of the shared data, creating a separate data processing relationship outside Walmart's direct control.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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