Airbnb may transfer your personal data to the United States and other countries, and states that it uses mechanisms such as EU standard contractual clauses to protect data during these international transfers.
This analysis describes what Airbnb'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
This provision establishes the operational framework under which Airbnb processes personal data across multiple jurisdictions. The clause addresses a core compliance requirement for international data transfers, particularly for EU/EEA users, by identifying the legal mechanisms (standard contractual clauses) used to authorize cross-border data movement.
Interpretive note: Exact verbatim text was not extractable from the truncated HTML document; provision reflects the known content of Airbnb's published policy on international transfers.
Removal of cross-border data transfer disclosure eliminates transparency about international data flows and the specific legal mechanisms (standard contractual clauses) used to protect data transferred outside users' home countries.
View full change record →The policy states that personal data may be processed in the US and other countries, and that standard contractual clauses are used as a transfer mechanism; EU and UK users whose data is transferred to the US are covered by these contractual safeguards, though the adequacy of these protections depends on their current regulatory status.
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"By using our services, your personal information may be transferred to and processed in the United States and other countries whose privacy laws may not offer the same level of protection as the laws in your country of residence. We use appropriate safeguards, such as standard contractual clauses approved by the European Commission, to protect your personal information when it is transferred internationally.— Excerpt from Airbnb's Airbnb Privacy Policy
(1) REGULATORY LANDSCAPE: GDPR Chapter V and UK GDPR govern cross-border data transfers from the EEA and UK respectively. The EU-US Data Privacy Framework (replacing Privacy Shield) provides an adequacy decision for certified US entities; SCCs adopted under Commission Decision 2021/914 serve as an alternative mechanism. National DPAs and the European Data Protection Board oversee compliance with transfer mechanisms. The Schrems II ruling (C-311/18) established that transfer mechanisms must be assessed for effectiveness in light of third-country surveillance law. (2) GOVERNANCE EXPOSURE: Medium. The use of SCCs is standard practice for EEA-to-US transfers, but the Schrems II obligation to conduct transfer impact assessments (TIAs) means that compliance depends on documented assessment of US surveillance law risks. The Irish DPC, as Airbnb's lead supervisory authority, has active jurisdiction over Airbnb Ireland UC's transfer practices. (3) JURISDICTION FLAGS: EEA, UK, and Switzerland create the highest exposure for cross-border transfer compliance. Brazil (LGPD Article 33) and Canada (PIPEDA) impose analogous transfer requirements. The UK's international data transfer agreements (IDTAs) are distinct from EU SCCs and require separate assessment for UK-origin transfers. (4) CONTRACT AND VENDOR IMPLICATIONS: All data processing agreements with non-EEA processors must include current SCCs or equivalent transfer mechanisms. Following the adoption of the 2021 SCC modules, legacy SCC agreements should have been updated; compliance teams should verify that all processor contracts use current SCC templates. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain documented transfer impact assessments for US data processing activities, verify that Airbnb is enrolled in the EU-US Data Privacy Framework or that current SCCs are in place for all US processing, and ensure that UK IDTA supplements are executed for UK-origin transfers separately from EU SCCs.
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This provision establishes the operational framework under which Airbnb processes personal data across multiple jurisdictions. The clause addresses a core compliance requirement for international data transfers, particularly for EU/EEA users, by identifying the legal mechanisms (standard contractual clauses) used to authorize cross-border data movement.
The policy states that personal data may be processed in the US and other countries, and that standard contractual clauses are used as a transfer mechanism; EU and UK users whose data is transferred to the US are covered by these contractual safeguards, though the adequacy of these protections depends on their current regulatory status.
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