Waze states that once your data is combined with others and stripped of identifying details, it is no longer considered personal information under this policy and can be shared with any party for any purpose without restriction.
This analysis describes what Waze'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 asserts a broad carve-out from the policy's privacy protections for aggregated or de-identified data, and does not specify a standard for what constitutes adequate de-identification or describe safeguards against re-identification.
Interpretive note: The policy does not specify the de-identification standard applied; under GDPR, data that Waze treats as anonymous may still constitute personal data if re-identification is reasonably possible, meaning the practical scope of this carve-out is legally uncertain in EU/EEA jurisdictions.
The updated policy now explicitly discloses that Waze periodically collects all phone numbers stored on your device's contact book as part of the 'find friends' feature. According to the revised term…
The updated policy removes explicit language describing how Waze collects phone numbers from device contact books and integrates social network accounts. Previously, the policy stated that Waze would…
The updated privacy policy now explicitly discloses that Waze periodically collects all phone numbers stored in your device's contact book as part of the 'find friends' feature. According to the poli…
The policy states that data Waze determines to be aggregated or de-identified falls outside the scope of its privacy commitments and can be shared without restriction; the practical scope of this carve-out depends on the de-identification standard applied, which the policy does not specify.
How other platforms handle this
We may use and share de-identified or aggregated information for any purpose, including research and analytics. We maintain and use de-identified data without attempting to re-identify it.
Mixpanel may use aggregated or de-identified data derived from customer event data for its own purposes, including improving its services, developing new features, and generating analytics insights, provided that such data cannot reasonably be used to identify individual users.
We may de-identify, anonymize, or aggregate information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. For example, we may disclose performance benchmark data and other aggregated, anonymized, or de-id...
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"We may use aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for any purpose, including sharing it with partners, advertisers, and other third parties. This information is not subject to the restrictions in this Privacy Policy.— Excerpt from Waze's Waze Privacy Policy
1) REGULATORY LANDSCAPE: GDPR does not exempt truly anonymous data from its scope, but the determination of whether data is genuinely anonymized (rather than merely pseudonymized) requires a high standard under the Article 29 Working Party and EDPB guidance; pseudonymized data remains personal data under GDPR. CCPA similarly provides a de-identification exception but requires companies to implement technical safeguards and contractual prohibitions on re-identification. The FTC has issued guidance cautioning that aggregation does not guarantee anonymization given re-identification research. 2) GOVERNANCE EXPOSURE: Medium. The provision's assertion that de-identified data is unrestricted is consistent with common industry practice but may overstate the legal position under GDPR, where the adequacy of anonymization is assessed contextually and regulatory guidance sets a high bar. Compliance teams should verify that the de-identification standard applied by Waze meets the EDPB's anonymization criteria and the CCPA's technical safeguard requirements. 3) JURISDICTION FLAGS: EU/EEA jurisdictions present the highest exposure given GDPR's strict anonymization standard; data that Waze treats as anonymous may still constitute personal data under GDPR if re-identification is reasonably possible given available means. California's CPRA maintains CCPA de-identification requirements including contractual prohibitions on downstream re-identification. 4) CONTRACT AND VENDOR IMPLICATIONS: Contracts with partners receiving de-identified data should include explicit prohibitions on re-identification consistent with CCPA requirements. Data processing agreements should specify the de-identification methodology applied. 5) COMPLIANCE CONSIDERATIONS: Legal teams should document the specific de-identification methodology used and assess it against EDPB anonymization guidance and CCPA technical safeguard standards. Periodic re-identification risk assessments should be conducted, particularly given the sensitivity of the underlying location and behavioral data.
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This provision asserts a broad carve-out from the policy's privacy protections for aggregated or de-identified data, and does not specify a standard for what constitutes adequate de-identification or describe safeguards against re-identification.
The policy states that data Waze determines to be aggregated or de-identified falls outside the scope of its privacy commitments and can be shared without restriction; the practical scope of this carve-out depends on the de-identification standard applied, which the policy does not specify.
ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.
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