Provision record
Brex · Brex Privacy Policy · View original document ↗

EEA Brex Dual Role as Processor and Controller

Medium severity Explicit document language Common · 279 of 352 platforms
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This analysis describes what Brex'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

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 3333 other provisions on other platforms.

How other platforms handle this

MyFitnessPal Medium

Send You Promotional and Marketing Materials Consent (where required by law) Legitimate Interests when consent is not required by law (specifically our interests in marketing features and products that may interest you...)

ZipRecruiter Medium

In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals...

Microsoft Medium

We do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files, to target advertising to you.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Brex may process personal information in accordance with the instructions of or on behalf of a business customer...Brex acts as a processor and the business customer acts as a controller. Brex may also act as a controller when directly determining the processing...

Excerpt from Brex's Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal

Provision details

Document information
Document
Brex Privacy Policy
Entity
Brex
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
July 9, 2026
Record ID
CA-P-049276
Document ID
CA-D-00534
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2d4e6b75544907e7cc81d201fac3c31caca2dfe4b400a05c23774fa9bf862362
Analysis generated
May 21, 2026 02:58 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Brex
Document: Brex Privacy Policy
Record ID: CA-P-049276
Captured: 2026-05-21 02:58:06 UTC
SHA-256: 2d4e6b75544907e7…
URL: https://conductatlas.com/platform/brex/brex-privacy-policy/provision/CA-P-049276/eea-brex-dual-role-as-processor-and-controller/
Accessed: Aug. 5, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

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Frequently Asked Questions

What does Brex's EEA Brex Dual Role as Processor and Controller clause do?

The clause states: “Brex may process personal information in accordance with the instructions of or on behalf of a business customer...Brex acts as a processor and the business customer acts as a controller. Brex may also act as a controller when directly determining the processing...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.

Is ConductAtlas affiliated with Brex?

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