Records / De-identification rules
The buyer commits, publicly and in writing
Every licence binds the buyer not to re-identify or try to, not to link the data with other data to identify people, to bind anyone it passes data to on the same terms, to tell you and us if it finds identifiable data, and to accept oversight. We make the same public commitment ourselves.
Dated 14 Aug 2026Source checked 15 Oct 2026Page out of reach at the last check, 17 Oct 2026Basis: our standard
“(2) Publicly commits to maintain and use the information in deidentified form and not to attempt to reidentify the information ... (3) Contractually obligates any recipients of the information to comply with all provisions of this subdivision.”
California Civil Code 1798.140(m), checked Aug 2024
Everything read from this source (3)Archived copy, 8 Sep 2026
In re Spirit Aviation Holdings, sale agreement, Dkt. 1463, s.1(c), checked 14 Aug 2026
Everything read from this source (5)Archived copy, 21 Aug 2026
FTC, Protecting Consumer Privacy in an Era of Rapid Change, 2012, checked 26 Mar 2012
- California Civil Code 1798.146: deidentified patient information outside the CCPA (Cal. Civ. Code 1798.146(a)(4))
- California Civil Code 1798.148: no re-identification, and required contract terms for selling deidentified patient information (Cal. Civ. Code 1798.148(a), (c))
- Spirit Airlines' de-identified enterprise data (email, Teams, OneDrive, SharePoint, CRM, revenue management, workflow data), Google's successful bid under the signed sale agreement
- Spirit Airlines' de-identified enterprise data, Mercor's alternate bid under its signed alternate sale agreement
- Certified de-identification is the closing condition, so payment waits for it
- Write the standard carve-outs into the records sale agreement
It is shown on its own, not counted into a figure.
Cited in these 2 guides