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Smartsheet updated its privacy policy on June 9, 2026 to clarify corporate structure and Data Privacy Framework participation. The policy previously stated that 'Smartsheet and its U.S. affiliates' participate in the EU-U.S., UK, and Swiss Data Privacy Frameworks. The updated language now specifies 'Smartsheet Inc.' and adds an explicit list of four U.S. affiliates that adhere to the DPF Principles: Artefact Product Group LLC (dba 10,000ft), Brandfolder Inc., On Brand Holdings Inc. (dba Outfit), and TernPro Inc. (dba Slope). This change provides clearer identification of which legal entities within the Smartsheet corporate group are responsible for complying with data transfer frameworks.
The updated policy clarifies the corporate structure and identifies specific U.S. entities within the Smartsheet group that are responsible for complying with international data transfer frameworks. Previously, the policy referred to 'Smartsheet and its U.S. affiliates' in general terms; the updated language now explicitly names Artefact Product Group LLC (10,000ft), Brandfolder Inc., On Brand Holdings Inc. (Outfit), and TernPro Inc. (Slope) as entities bound by the Data Privacy Framework Principles. This provides greater specificity about which entities handle personal data subject to cross-border transfer protections.
The updated policy provides explicit identification of which corporate entities within the Smartsheet group are responsible for Data Privacy Framework compliance. This clarification supports organizations in documenting lawful data transfer mechanisms and conducting vendor due diligence, as required by GDPR Chapter V and equivalent UK and Swiss legal frameworks.
Updated to explicitly name four U.S. affiliate entities (10,000ft, Brandfolder, Outfit, Slope) as entities adhering to DPF Principles
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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
This change updates the privacy policy to explicitly identify which U.S. subsidiary entities participate in the Data Privacy Framework. The change is primarily clarificatory rather than substantive, replacing a general reference to 'affiliates' with specific entity names. Organizations relying on Smartsheet's DPF certification for lawful data transfers should confirm that all relevant entities are included in their vendor assessments and data processing agreements. No new compliance obligations appear to be created by this change; rather, it provides enhanced transparency regarding existing commitments.
Regulatory exposure, obligation analysis, escalation trigger, board language, and recommended action.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-002781.
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