Adyen can process your personal data without your consent in certain cases where it believes its business reasons, like preventing fraud or improving its products, outweigh your privacy interests.
This analysis describes what Adyen'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
Legitimate interests is a flexible legal basis that does not require your consent, meaning Adyen can process your data for analytics and product improvement without asking you, though you have the right to object to such processing.
Interpretive note: The adequacy of the balancing test Adyen performs for legitimate interests purposes is not publicly documented, creating uncertainty about whether specific processing categories would withstand regulatory challenge.
Adyen's use of legitimate interests as a processing basis for product improvement and direct marketing means your behavioral and transaction data may be analyzed for these purposes without explicit opt-in consent, though you can object to this processing by contacting Adyen.
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"We process your personal data based on our legitimate interests, such as to prevent fraud, ensure the security of our services, improve our products and services, and for direct marketing purposes. When we process your personal data based on our legitimate interests, we always weigh these interests against your rights and interests.— Excerpt from Adyen's Adyen Privacy Policy
REGULATORY LANDSCAPE: This provision engages GDPR Article 6(1)(f), which requires a documented balancing test between the controller's legitimate interests and the data subject's fundamental rights. The UK GDPR contains equivalent provisions. Under GDPR, reliance on legitimate interests for direct marketing is specifically addressed in Recital 47. The Dutch Autoriteit Persoonsgegevens and UK ICO have both issued guidance on what constitutes an adequate Legitimate Interests Assessment. GOVERNANCE EXPOSURE: Medium. The breadth of purposes claimed under legitimate interests, spanning fraud prevention, security, product analytics, and direct marketing, warrants documented Legitimate Interests Assessments for each category. The policy states that a balancing exercise is performed but does not publish those assessments, which is permissible but may face scrutiny if challenged. JURISDICTION FLAGS: EU and UK create primary exposure. California's CPRA does not use legitimate interests terminology but imposes restrictions on use of personal information beyond disclosed purposes, which may require evaluation of whether Adyen's analytics use cases are adequately disclosed to California residents. CONTRACT AND VENDOR IMPLICATIONS: Merchants whose customer data Adyen processes should confirm whether Adyen's legitimate interests claims in a controller context affect data that originates from the merchant's transactions. If so, merchant privacy notices may need to disclose Adyen's analytics use of transaction data. COMPLIANCE CONSIDERATIONS: Legal teams should request copies of Adyen's Legitimate Interests Assessments for high-risk processing categories, particularly where special category data or financial data is involved. The right to object under GDPR Article 21 should be operationally tested to ensure Adyen's process for handling objections is functional and timely.
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Legitimate interests is a flexible legal basis that does not require your consent, meaning Adyen can process your data for analytics and product improvement without asking you, though you have the right to object to such processing.
Adyen's use of legitimate interests as a processing basis for product improvement and direct marketing means your behavioral and transaction data may be analyzed for these purposes without explicit opt-in consent, though you can object to this processing by contacting Adyen.
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