The policy authorizes sharing personal information with service providers performing functions including payment processing, data analysis, email delivery, hosting, customer service, and marketing, subject to a contractual limitation that restricts these providers to use the data only for the stated service purposes.
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
This provision establishes the contractual framework for vendor data sharing and the scope of permitted downstream use, which is directly relevant to CCPA service provider qualification, GDPR processor agreement requirements, and GLBA information security program obligations.
Interpretive note: The source document was truncated; specific verbatim language reflects available policy content. The full list of service provider categories may not be visible in the truncated document.
Under this clause, personal information is shared with vendors performing operational functions for Brex; these vendors are described as contractually limited to using the data only to perform services for Brex.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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"We share personal information with third-party service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. These service providers are authorized to use your personal information only as necessary to provide services to us.— Excerpt from Brex's Brex Privacy Policy
(1) REGULATORY LANDSCAPE: CCPA/CPRA requires that service providers who receive personal information be bound by written contracts prohibiting them from using data for purposes other than specified services, and from selling or sharing that data. GDPR Article 28 requires written processor agreements specifying processing purposes, data categories, and security obligations. GLBA requires that service provider relationships include contractual safeguards for customer financial information. (2) GOVERNANCE EXPOSURE: Medium. The policy asserts a use limitation on service providers, but compliance teams must verify that executed contracts with each vendor include CCPA-compliant service provider terms and GDPR-compliant processor agreements. (3) JURISDICTION FLAGS: California requires that service provider contracts include CPRA-specified prohibitions. EU law requires Article 28 processor agreements for all vendors processing EU personal data. Financial service providers are subject to GLBA contractual requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and vendor management teams should confirm that all vendors receiving personal information have executed agreements that include required CCPA service provider terms, GDPR Article 28 clauses, and GLBA safeguarding provisions. (5) COMPLIANCE CONSIDERATIONS: Conduct a vendor inventory mapped to data categories shared; verify contract coverage for CCPA, GDPR, and GLBA requirements; and confirm that subprocessor chains are disclosed and covered by appropriate contractual protections.
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This provision establishes the contractual framework for vendor data sharing and the scope of permitted downstream use, which is directly relevant to CCPA service provider qualification, GDPR processor agreement requirements, and GLBA information security program obligations.
Under this clause, personal information is shared with vendors performing operational functions for Brex; these vendors are described as contractually limited to using the data only to perform services for Brex.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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