Smartsheet modified a single sentence in its Privacy Policy on June 5, 2026 describing which entities participate in the EU-U.S. Data Privacy Framework. The updated language specifies that 'Smartsheet and its U.S. affiliates' participate in the framework, whereas the previous version stated 'Smartsheet and its affiliates' without the geographic qualifier. This change narrows the scope of framework participation to U.S.-based affiliates only, which may affect how personal data transfers are handled for non-U.S. affiliated entities.
The updated privacy policy states that only Smartsheet's U.S.-based affiliates participate in the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework. Previously, the policy referenced participation by Smartsheet and its affiliates without geographic qualification. This narrowed scope may affect the data transfer mechanisms available for processing personal data from EU, UK, and Swiss users if non-U.S. affiliates are involved in data handling. The policy does not explicitly describe alternative transfer mechanisms for non-U.S. affiliates.
Participation narrowed to U.S. affiliates only; prior language did not specify geographic scope
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
Smartsheet's June 5, 2026 privacy policy update narrows Data Privacy Framework participation to U.S. affiliates only. This change introduces potential ambiguity about legal mechanisms governing data transfers by non-U.S. Smartsheet entities, which may implicate GDPR …
Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.
Unlock the full institutional analysis — InsightConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-002714.
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