Checkout.com · Checkout.com Privacy · View original document ↗

Controller vs Processor Dual Role

High severity Rare · 1 of 325 platforms
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This analysis describes what Checkout.com'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)

This provision establishes the legal responsibility framework for personal data processing. The allocation of controller and processor roles determines which entity bears regulatory compliance obligations under data protection law, including responding to data subject access requests and implementing data protection safeguards.

Consumer impact (what this means for users)

Users of Checkout.com's services operate under different privacy governance depending on whether they interact with Checkout.com directly (where Checkout.com controls their data) or through a merchant (where the merchant's privacy policy applies and data subject requests must be directed to the merchant). This structure means end customers should direct data access requests to their merchant rather than directly to Checkout.com for transaction-related processing.

How other platforms handle this

DocuSign Medium

When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certa...

Anthropic Medium

This Privacy Policy does not apply where Anthropic acts as a data processor and processes personal data on behalf of commercial customers using Anthropic's Commercial Services – for example, your employer has provisioned you a Claude for Work account, or you're using an app that is powered on the ba...

Smartsheet Medium

When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...

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▸ View Original Clause Language DOCUMENT RECORD
"
Checkout.com acts as a data controller in respect of the personal data of its own business contacts and website visitors. Where Checkout.com processes personal data on behalf of its merchant clients in connection with the provision of payment services, Checkout.com acts as a data processor and the merchant is the data controller. In such cases, the merchant's privacy policy will govern the processing of end customer personal data and any data subject requests should be directed to the relevant merchant.

— Excerpt from Checkout.com's Checkout.com Privacy

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
Checkout.com Privacy
Entity
Checkout.com
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-006968
Document ID
CA-D-00663
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a644fb34e781c2f85b7f4158747e8b392097069bd33d31e2fe9cda04abdf18be
Analysis generated
May 8, 2026 15:31 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Checkout.com
Document: Checkout.com Privacy
Record ID: CA-P-006968
Captured: 2026-05-08 15:31:40 UTC
SHA-256: a644fb34e781c2f8…
URL: https://conductatlas.com/platform/checkoutcom/checkoutcom-privacy/controller-vs-processor-dual-role/
Accessed: May 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 Checkout.com's Controller vs Processor Dual Role clause do?

This provision establishes the legal responsibility framework for personal data processing. The allocation of controller and processor roles determines which entity bears regulatory compliance obligations under data protection law, including responding to data subject access requests and implementing data protection safeguards.

How does this clause affect you?

Users of Checkout.com's services operate under different privacy governance depending on whether they interact with Checkout.com directly (where Checkout.com controls their data) or through a merchant (where the merchant's privacy policy applies and data subject requests must be directed to the merchant). This structure means end customers should direct data access requests to their merchant rather than directly to Checkout.com …

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with Checkout.com?

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