You are prohibited from using Adobe's services to store, process, or share sensitive categories of personal data, including health information, financial data, biometric data, and children's personal information.
This analysis describes what Adobe's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Users who attempt to store health records, financial documents, or other sensitive personal information in Adobe cloud services may be in violation of these terms, and Adobe is not obligated to protect such data as a covered entity under applicable health or financial privacy laws.
Uploading health, financial, biometric, or children's personal information to Adobe cloud services is restricted by these terms, and Adobe is not a HIPAA-covered entity; users storing such data assume significant compliance and liability risk.
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"You agree not to collect, process, or store any Sensitive Personal Information (as defined below) using the Services and Software, except as (A) directly authorized by Adobe, (B) intended by the Services and Software, or (C) governed by the Product Specific Terms, as applicable. You agree not to transmit, disclose, or make available Sensitive Personal Information to Adobe or Adobe's third-party providers. "Sensitive Personal Information" means an individual's financial information, data concerning an individual's sexual behavior or sexual orientation, medical, or health information protected under any health data protection laws, biometric data, personal information of children protected under any child data protection laws (such as the personal information defined under the U.S. Children's Online Privacy Protection Act ("COPPA")) and any additional types of information included within this term or any similar term (such as "sensitive personal data" or "special categories of personal information") as used in applicable data protection or privacy laws.— Excerpt from Adobe's Adobe Terms of Use
(1) REGULATORY LANDSCAPE: This provision directly engages HIPAA (health data), COPPA (children's personal information), GLBA (financial information), and GDPR's special categories provisions (Article 9) for EU users. Adobe's explicit prohibition on sensitive personal information upload reflects its position as a general-purpose software platform rather than a HIPAA Business Associate, and the terms do not establish a Business Associate Agreement. Organizations in healthcare, financial services, or education should treat this provision as a categorical restriction on use case scope. (2) GOVERNANCE EXPOSURE: High for regulated industries. Healthcare organizations using Adobe products to process or store patient information without explicit Adobe authorization risk both terms violations and potential HIPAA non-compliance. Financial services firms should assess whether use of Adobe cloud services for document processing could implicate GLBA safeguards requirements. (3) JURISDICTION FLAGS: EU and EEA users face GDPR Article 9 restrictions on processing special categories of personal data; this provision aligns with those requirements but places the compliance obligation on the user rather than Adobe. California CPRA's treatment of sensitive personal information creates additional compliance considerations for California-based businesses. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams in regulated industries should confirm that use cases for Adobe products do not involve sensitive personal information as defined in this provision. If regulated data processing is required, organizations should seek explicit Adobe authorization or evaluate whether product-specific terms provide a carve-out. (5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should document this provision in their data classification and vendor management frameworks, and include it in acceptable use policies distributed to employees. Healthcare and financial services organizations should conduct a use case review to confirm Adobe deployments do not inadvertently involve prohibited data categories.
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Users who attempt to store health records, financial documents, or other sensitive personal information in Adobe cloud services may be in violation of these terms, and Adobe is not obligated to protect such data as a covered entity under applicable health or financial privacy laws.
Uploading health, financial, biometric, or children's personal information to Adobe cloud services is restricted by these terms, and Adobe is not a HIPAA-covered entity; users storing such data assume significant compliance and liability risk.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Adobe.