Adobe · Adobe Terms of Use · View original document ↗

Sensitive Personal Information Prohibition

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause establishes Adobe's operational boundary regarding data categories that cannot be processed through its platform without explicit authorization. It creates a contractual allocation of responsibility that requires users to implement controls to prevent certain data types from entering Adobe's systems, reducing Adobe's liability exposure for processing restricted categories and ensuring compliance with health, child protection, and data protection regulations.

Consumer impact (what this means for users)

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.

How other platforms handle this

OpenAI Medium

Don't claim to be human when directly and sincerely asked, use AI to deceive people about its fundamental nature, or impersonate real people or organizations in misleading ways.

Runway Medium

You may not use Runway's tools to build or support systems designed for mass surveillance, tracking of individuals without their consent, or the unlawful monitoring of protected groups or activities.

Midjourney Medium

Do not generate images for political campaigns or to try to influence the outcome of an election. Do not generate images to spread misinformation or disinformation.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • Hhs Ocr
    HHS OCR enforces HIPAA; healthcare organizations using Adobe to process protected health information without a Business Associate Agreement may face enforcement exposure.
    File a complaint →
  • FTC
    The FTC has authority over unfair or deceptive practices involving consumer health and financial data, and oversees COPPA compliance for children's personal information.
    File a complaint →

Applicable regulations

CFAA
United States Federal
DMCA
United States Federal
DSA
European Union

Provision details

Document information
Document
Adobe Terms of Use
Entity
Adobe
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
May 11, 2026
Record ID
CA-P-001066
Document ID
CA-D-00199
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9cc2260378e6e0dd747c9fd82223c925a9726b28cc700b53d17dd54f1e17eb04
Analysis generated
March 20, 2026 04:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Adobe
Document: Adobe Terms of Use
Record ID: CA-P-001066
Captured: 2026-03-20 04:51:07 UTC
SHA-256: 9cc2260378e6e0dd…
URL: https://conductatlas.com/platform/adobe/adobe-terms-of-use/sensitive-personal-information-prohibition/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Adobe's Sensitive Personal Information Prohibition clause do?

This clause establishes Adobe's operational boundary regarding data categories that cannot be processed through its platform without explicit authorization. It creates a contractual allocation of responsibility that requires users to implement controls to prevent certain data types from entering Adobe's systems, reducing Adobe's liability exposure for processing restricted categories and ensuring compliance with health, child protection, and data protection regulations.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Adobe?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Adobe.