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The policy states that Google does not sell personal information and does not share it as defined under the CCPA, and discloses that U.S. state privacy laws provide users rights to access, correct, delete, and port their data, as well as opt out of profiling and targeted advertising.
This analysis describes what YouTube Ads'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 makes a material legal representation that Google's data practices do not constitute a sale or CCPA-defined share of personal information, which is significant given the breadth of Google's advertising and data partnerships. The enumeration of state privacy rights establishes the operative framework for user rights requests across approximately twenty U.S. jurisdictions.
Interpretive note: The accuracy of the CCPA non-sale and non-share representation relative to Google's advertising data flows with third-party partners is a legal determination that depends on the specific mechanics of those data flows and applicable regulatory interpretation, which cannot be fully assessed from the policy text alone.
The updated policy makes several material clarifications about how Google links your activity across websites and apps. It shifts from describing analytics tools in isolation to framing them as part of a broader 'ad and analytics services' ecosystem, and broadens the scope of data linking to explicitly include 'cookies and other technologies'. The policy also clarifies that data sharing occurs even in private browsing modes. Review your Google Account activity controls to understand what data is being collected and linked across services you use.
View change record →Under this clause, Google represents that it does not sell personal data or share it under the CCPA definition, and acknowledges user rights under approximately twenty U.S. state privacy laws including access, correction, deletion, data portability, and opt-out from targeted advertising. The agreement states that rights requests can be submitted through Google's account tools or by contacting Google directly.
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"Google does not sell your personal information. Google also does not 'share' your personal information as that term is defined in the California Consumer Privacy Act (CCPA). U.S. state privacy laws also provide the right to request information about how Google collects, uses, and discloses your information. And they give you the right to access your information, sometimes in a portable format; correct your information; and to request that Google delete that information. Many of these laws also provide the right to opt out of certain forms of profiling and targeted advertising.Excerpt from YouTube Ads's Google Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly engages the CCPA and CPRA, enforced by the California Privacy Protection Agency (CPPA) and California Attorney General, and the approximately eighteen additional state privacy statutes enumerated in the policy. The representation that Google does not 'sell' or 'share' under CCPA definitions is a material compliance assertion subject to CPPA scrutiny, given the scope of Google's advertising data flows. 2. GOVERNANCE EXPOSURE: Medium. The non-sale and non-share representation is significant and if inaccurate could constitute a violation of CCPA enforceable by the CPPA with civil penalties. The breadth of Google's advertising partnerships and cross-context behavioral advertising practices means this representation may attract regulatory attention regarding whether advertising-related data flows constitute 'sharing' under CCPA's definition. 3. JURISDICTION FLAGS: California users have the most developed enforcement framework through the CPPA. Users in Virginia, Colorado, Connecticut, Utah, and the other enumerated states have access to rights under their respective statutes, with enforcement by state attorneys general. The policy's enumeration of twenty-plus state laws reflects the current landscape but should be monitored as additional state laws take effect. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations that rely on Google's CCPA non-sale representation in their own vendor due diligence should assess whether advertising data flows between their platforms and Google, through tools like Google Analytics and Google Ads, are consistent with this representation in the context of their own CCPA compliance obligations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should document the basis for Google's non-sale and non-share representations relative to advertising data flows, and ensure that their own privacy notices accurately characterize data sharing arrangements with Google. State privacy law rights request procedures should be reviewed to confirm they align with the rights enumerated in this provision across all applicable jurisdictions.
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This provision makes a material legal representation that Google's data practices do not constitute a sale or CCPA-defined share of personal information, which is significant given the breadth of Google's advertising and data partnerships. The enumeration of state privacy rights establishes the operative framework for user rights requests across approximately twenty U.S. jurisdictions.
Under this clause, Google represents that it does not sell personal data or share it under the CCPA definition, and acknowledges user rights under approximately twenty U.S. state privacy laws including access, correction, deletion, data portability, and opt-out from targeted advertising. The agreement states that rights requests can be submitted through Google's account tools or by contacting Google directly.
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