{"page":"/blog/glba-service-provider-exception-advertising","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Reading","What it holds","What it relies on","What it means for a design"],"rows":[["A cautious reading","The exception covers vendors that work for the institution to market the institution's own products. A merchant, or a DSP that acts for a merchant, uses the audience to promote the merchant's brand and performs no service for the institution. That disclosure needs the notice and opt-out route, or it must be limited to outputs that are not NPI.","The words \"to perform services for you or functions on your behalf\"; the limit of joint marketing to financial institutions","Merchants receive aggregates only, or the audience is built from consumers who have not opted out"],["A permissive reading","A merchant-funded offers program is the institution's own rewards product. Vendors that deliver and measure those offers, on or off the institution's own channels, serve the institution under a contract that limits use. The exception applies to them.","1016.13(b), marketing of \"your own products or services\"; the use-limiting contract","Offsite delivery runs through vendors bound by contract, with the institution as the advertiser of record"]],"sourceUrls":[[],[]]}