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Summary
Generated by a model from the captured document; not read by a person

This is Checkout.com's global privacy notice describing how the company collects and uses personal data when providing payment processing, fraud detection, and identity verification services to three groups: the businesses it works with (Merchant Representatives), the consumers who transact through those businesses (Merchant Customers), and visitors to its website. The notice discloses that Merchant Customers' biometric data, including facial images and voiceprints, is collected during identity verification, shared with Snowflake Computing and Amazon Web Services, and retained for up to 365 days, with processing conditional on explicit consent. The notice also discloses that automated decision-making is used for fraud detection and identity verification, which may result in transactions being declined or access to services being delayed or denied, and that affected individuals may have the right to request human review of those decisions depending on their jurisdiction.

Analysis

This document is Checkout.com's global Privacy Notice, last updated 19 June 2026, governing how the Checkout.com group processes personal data across three distinct user categories: Merchant Representatives, Merchant Customers, and Website Users, with legal bases including legitimate interests, legal obligation, contractual necessity, and explicit consent depending on the data type and processing purpose. The notice states that Checkout collects contact information, cardholder data, transaction data, device and technical identifiers, identity verification documents, and biometric data including facial images and voiceprints, with the notice further disclosing that biometric data is shared with third-party cloud providers Snowflake Computing and Amazon Web Services and retained for up to 365 days. The biometric data collection and processing provisions, including automated identity verification and a 96-hour temporary image-hash blocking mechanism, are operationally distinct relative to standard payment processor privacy notices and engage multiple state-level biometric privacy frameworks; the notice asserts consent as the legal basis for biometric processing but the enforceability and sufficiency of that consent mechanism may vary by jurisdiction. The notice engages GDPR and UK GDPR for EEA and UK data subjects, CCPA and CPRA for California residents, the Colorado Privacy Act, Australian Privacy Principles, Brazil's LGPD, and French Law No. 78-17 Article 85, with country-specific supplements addressing supplemental rights, complaint escalation paths to the ICO, OAIC, and relevant state authorities, and SCCs or ICO-approved clauses used for international data transfers from the UK and EEA.

What this means for you

The agreement establishes that Merchant Customers' biometric data, including facial images and voiceprints, may be collected, processed, and shared with third-party cloud providers Snowflake Computing and Amazon Web Services, subject to explicit consent, and retained for up to 365 days before deletion. Under these terms, automated decision-making for fraud detection and identity verification may result in a transaction being declined or access to a product or service being delayed or denied, with the notice stating that affected individuals in certain jurisdictions may request human review of automated decisions. You can opt out of direct marketing at any time via the unsubscribe link in marketing emails or by contacting dpo@checkout.com, and you can submit data rights requests including access, correction, erasure, and objection to automated decisions by contacting dpo@checkout.com.

Institutional Analysis
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1 important change detected

10 versions captured · Latest change detected by ConductAtlas: July 2026

July 8, 2026

medium
What changed Checkout.com expanded its privacy policy to explicitly disclose that it uses recordings of calls with merchants for training, product development, and marketing purposes. The updated policy also clarifies how it processes contact, cardholder, transaction, and technical information for merchant customers, including for fraud detection and regulatory compliance. This change adds specificity to data processing practices for both merchant representatives and merchant customers, establishing lawful bases for each use case.
Why this matters The updated policy explicitly states that Checkout.com uses recordings of calls with merchants for training, product development, and marketing purposes. The policy also clarifies that merchant customer contact, cardholder, transaction, and technical information is processed to deliver payment services, detect fraud, and comply with legal obligations. Merchants and their customers should review the updated disclosure to understand how their communications and transaction data are used.
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Provisions
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Archival ProvenanceSource & Archival Record
This version captured September 29, 2026 01:14 UTC
Last successful capture October 21, 2026 00:54 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000663
Version ID CA-V-007201
SHA-256 (extracted text, extractor v5) 1175dff36fd36d64bb4ac6edacd9c5381fa9268474004bf78c383c02737f0ac3
Archived bytes SHA-256 (anchor) ea0090cf400b3b347f0f5bbd6446b38bee256baa3327fad4f9061e1606a6f402
✓ Snapshot stored ✓ Archived bytes anchored (verified Sept. 29, 2026)

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