Provision record
AWS · AWS Customer Agreement · View original document ↗

Data Processing and Privacy Addendum Structure

High severity Medium confidence Explicit document language Common · 288 of 352 platforms
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Document Record

What it is

AWS processes your data only to run the services you use, not for its own marketing or product purposes, and it offers a separate Data Processing Addendum for customers who need it to comply with GDPR or similar laws.

This analysis describes what AWS'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)

The Data Processing Addendum is a separate document that must be actively executed by customers who process personal data subject to GDPR or similar frameworks; it is not automatically incorporated into the main agreement.

Interpretive note: The specific contractual requirements for GDPR Article 28 compliance depend on the version of the DPA in effect and the nature of the personal data processed; legal review of the current DPA text is required to confirm adequacy.

Consumer impact (what this means for users)

Customers who process personal data of individuals in the EU, UK, or other regulated jurisdictions must execute a separate Data Processing Addendum with AWS to establish the legally required controller-processor relationship. Without this addendum, the customer's data processing activities on AWS may lack the contractual safeguards required by GDPR and similar laws.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Navigate to the AWS Data Privacy page to review and execute the Data Processing Addendum applicable to your account if you process personal data subject to GDPR, UK GDPR, or similar frameworks.

How other platforms handle this

Squarespace Medium

Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).

Google Gemini Medium

The Gemini Apps Privacy Notice does not apply, and your Opal data, including feedback you provide, is processed per the Google Privacy Policy.

FanDuel Medium

Recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as your country.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
The AWS Privacy Notice describes our privacy practices. Each party will comply with applicable data protection laws in connection with the Service Offerings. AWS will process Customer Data only to provide the Service Offerings and related support and not for its own purposes, except as described in the AWS Privacy Notice or as you otherwise consent. AWS offers a Data Processing Addendum for customers who require one for GDPR or other legal compliance purposes.

Excerpt from AWS's Customer Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: GDPR Article 28 requires a written contract between data controllers and processors specifying the subject matter, duration, nature, and purpose of processing.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
AWS Customer Agreement
Entity
AWS
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 9, 2026
Record ID
CA-P-007748
Document ID
CA-D-00674
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6d114216458bb84e7194307cffc74be1120fd6e465c1ce76a207512b61effe42
Analysis generated
May 8, 2026 03:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: AWS
Document: AWS Customer Agreement
Record ID: CA-P-007748
Captured: 2026-05-08 03:04:08 UTC
SHA-256: 6d114216458bb84e…
URL: https://conductatlas.com/platform/aws/aws-customer-agreement/provision/CA-P-007748/data-processing-and-privacy-addendum-structure/
Accessed: Sept. 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does AWS's Data Processing and Privacy Addendum Structure clause do?

The Data Processing Addendum is a separate document that must be actively executed by customers who process personal data subject to GDPR or similar frameworks; it is not automatically incorporated into the main agreement.

How does this clause affect you?

Customers who process personal data of individuals in the EU, UK, or other regulated jurisdictions must execute a separate Data Processing Addendum with AWS to establish the legally required controller-processor relationship. Without this addendum, the customer's data processing activities on AWS may lack the contractual safeguards required by GDPR and similar laws.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.

Is ConductAtlas affiliated with AWS?

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