What did your privacy policy, terms of service and employee handbook say about sharing or selling data at the time it was collected?
The policies in force when the data was collected allowed this kind of transfer, or affected people gave fresh affirmative consent, or the data is fully anonymised.
Dated 11 Oct 2026Source checked 11 Oct 2026Quote found on its page again 16 Oct 2026Basis: stated
In the source's own words
“A business that collects user data based on one set of privacy commitments cannot then unilaterally renege ... It may be unfair or deceptive for a company to adopt more permissive data practices ... through a surreptitious, retroactive amendment to its terms of service or privacy policy.”
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Cited in these 3 guides