X · X Privacy Policy · View original document ↗

Ad Partner Data Combination and Off-Platform Tracking

Medium severity Unique · 0 of 352 platforms
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Document Record

What it is

This provision states that X receives browser cookie IDs, device IDs, hashed email addresses, demographic data, and behavioral data from ad partners, and may collect similar data directly from advertiser websites and apps via integrated advertising technology; this data may be combined with user-provided and platform-collected data.

This analysis describes what X'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause establishes that X's data collection extends to off-platform behavioral data sourced from advertiser websites and apps, and that this data is combined with on-platform data to build user profiles for advertising purposes. The scope of this data combination is relevant to GDPR's transparency requirements and CCPA's disclosure obligations for data collected from third-party sources.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to Settings, then Privacy and Safety, and review advertising data and data sharing with business partners settings to adjust how ad partner data is used.

If You Do Nothing

The terms permit X to combine off-platform ad partner data with user account data for advertising purposes as described unless the user adjusts advertising-related privacy settings

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Our ad and business partners share information with us such as browser cookie IDs, X-generated identifiers, mobile device IDs, hashed user information like email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Some of our ad partners, particularly our advertisers, also enable us to collect similar information directly from their website or app by integrating our advertising technology. Information shared by ad partners and affiliates or collected by X from the websites and apps of ad partners and affiliates may be combined with the other information you share with X and that X receives, generates, or infers about you described elsewhere in this Privacy Policy.

Excerpt from X's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision engages GDPR's transparency, purpose limitation, and third-party data sourcing requirements, CCPA's right to know about sources of personal information, and FTC guidelines on online behavioral advertising and data broker practices. The Irish DPC has authority for EU and EEA users; the FTC has authority for US users. 2) GOVERNANCE EXPOSURE: Medium. The combination of off-platform behavioral data with on-platform data for advertising profiling is a standard industry practice but is subject to increasing regulatory scrutiny, particularly in the EU where GDPR requires disclosure of third-party data sources and may require a documented lawful basis for this processing. California residents have a right under CCPA to know the categories of sources from which personal information is collected. 3) JURISDICTION FLAGS: EU and EEA users may have rights to object to processing for direct marketing and to obtain information about third-party data sources under GDPR. California residents are entitled to know about third-party data sources and to opt out of the sale or sharing of their personal information, which the combined profiling practice may constitute under CPRA. Washington and Oregon residents have similar rights under their state privacy laws. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertisers who integrate X's advertising technology on their websites or apps should ensure that their own privacy notices disclose this data sharing to their users. Failure to do so may create liability for the advertiser under applicable privacy law, independent of X's obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether X's opt-out mechanisms for advertising data sharing are operationally effective and consistent with the scope of data combination described in this provision. Privacy notices and cookie consent banners deployed by advertisers using X technology should be reviewed to ensure they accurately describe data flows to X.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over online behavioral advertising practices and data broker data combination under its consumer protection mandate.
    File a complaint →
  • State AG
    California, Washington, and Oregon attorneys general have jurisdiction over third-party data sourcing and combination practices under CPRA, the My Health My Data Act, and OCPA respectively.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
X Privacy Policy
Entity
X
Document last updated
May 5, 2026
Tracking information
First tracked
July 16, 2026
Last verified
July 16, 2026
Record ID
CA-P-00030003
Document ID
CA-D-00030
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
96e2de581453db81d042d438707291805a0ff232974c94facff2345c03383b3e
Analysis generated
July 16, 2026 01:47 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: X
Document: X Privacy Policy
Record ID: CA-P-00030003
Captured: 2026-07-16 01:47:25 UTC
SHA-256: 96e2de581453db81…
URL: https://conductatlas.com/platform/x/x-privacy-policy/ad-partner-data-combination-and-off-platform-tracking/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does X's Ad Partner Data Combination and Off-Platform Tracking clause do?

This clause establishes that X's data collection extends to off-platform behavioral data sourced from advertiser websites and apps, and that this data is combined with on-platform data to build user profiles for advertising purposes. The scope of this data combination is relevant to GDPR's transparency requirements and CCPA's disclosure obligations for data collected from third-party sources.

Is ConductAtlas affiliated with X?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by X.