Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
Zendesk acknowledges that its routine data sharing with advertising and cookie technology partners on its digital properties may qualify as a 'sale' or 'sharing' under California law, though no monetary exchange for data is described.
This analysis describes what Zendesk'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 constitutes Zendesk's acknowledgment that its advertising and tracking technology practices trigger CCPA and CPRA sale and sharing obligations, establishing the legal basis for California residents' opt-out rights and the associated compliance mechanisms described elsewhere in the notice.
Under this clause, Zendesk's disclosure to advertising partners of identifiers, browsing activity, and geolocation data through cookie and tracking technologies is treated as a potential California 'sale' or 'sharing,' entitling California residents to opt-out rights as described in Section 10 of the notice.
Cross-platform context
See how other platforms handle Advertising Partner Data Sharing as Potential California Sale and similar clauses.
Compare across platforms →Monitoring
Zendesk has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"Although we have not 'sold' or 'shared' personal data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a 'sale' or 'sharing' as defined under California law. We do not knowingly sell or share any personal data of minors under the age of 16.Excerpt from Zendesk's Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly implicates the CCPA and CPRA definitions of 'sale' and 'sharing,' enforced by the California Privacy Protection Agency and the California Attorney General. The CPRA's definition of 'sharing' encompasses cross-context behavioral advertising even without monetary exchange, and Zendesk's acknowledgment aligns with this interpretation. 2. GOVERNANCE EXPOSURE: Medium. The acknowledgment that routine advertising practices may constitute a California sale or sharing is a compliance-relevant disclosure that triggers opt-out obligations. The adequacy of Zendesk's two-step opt-out mechanism (addressed separately) is the primary governance exposure point associated with this acknowledgment. 3. JURISDICTION FLAGS: This disclosure is specifically framed under California law. Other states with comprehensive privacy laws that include opt-out rights for targeted advertising (such as Colorado, Virginia, and Connecticut) may impose similar obligations, and Zendesk's notice does not explicitly address compliance with those frameworks beyond California. 4. CONTRACT AND VENDOR IMPLICATIONS: Businesses using Zendesk's digital properties as part of their own customer-facing technology stack should assess whether Zendesk's advertising data flows affect their own CCPA compliance obligations, particularly if they have configured Zendesk tools that interact with end-user data. 5. COMPLIANCE CONSIDERATIONS: Legal teams should confirm that Zendesk's identification of advertising partner data flows as potential sales or sharing is accurately reflected in the organization's data mapping and vendor records. For organizations subject to CCPA as businesses, the use of Zendesk's digital properties as a marketing or sales platform should be assessed for downstream data sharing implications.
This provision constitutes Zendesk's acknowledgment that its advertising and tracking technology practices trigger CCPA and CPRA sale and sharing obligations, establishing the legal basis for California residents' opt-out rights and the associated compliance mechanisms described elsewhere in the notice.
Under this clause, Zendesk's disclosure to advertising partners of identifiers, browsing activity, and geolocation data through cookie and tracking technologies is treated as a potential California 'sale' or 'sharing,' entitling California residents to opt-out rights as described in Section 10 of the notice.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Zendesk.