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

Legitimate Interests as Legal Basis

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
Stay ahead of the changes
Track Checkout.com and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

Checkout.com uses 'legitimate interests' as a legal reason to process personal data for fraud prevention, security, service improvement, and business marketing without requiring your explicit consent in each case.

ⓘ

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)

Legitimate interests is a flexible but contested legal basis under GDPR; individuals have the right to object to processing on this basis, and Checkout.com must stop unless it can demonstrate compelling grounds that override the individual's interests.

⚠

Interpretive note: The sufficiency of legitimate interests as a legal basis for specific processing activities depends on documented LIA outcomes and regulatory interpretation, which vary by jurisdiction and processing context.

Recent Activity

This document changed recently

Medium Jun 19, 2026

The updated policy establishes formal complaint procedures for UK and Australia users, requiring Checkout to acknowledge complaints within 30 days and respond without undue delay. For UK users specifically, the policy clarifies that complaints must first be raised with Checkout before escalating to the Information Commissioner's Office. The policy also discloses that transaction information collection now includes country data alongside currency and amount. For Australia users, the policy clarifies that identity verification is a legal requirement and cannot be provided anonymously or pseudonymously. Users in these jurisdictions can submit data protection complaints through Checkout's designated process and escalate to their respective regulatory authorities if dissatisfied with Checkout's response.

View change record →

Consumer impact (what this means for users)

Processing on legitimate interests grounds means Checkout.com may use personal data for fraud prevention, analytics, and marketing to business contacts without asking for consent each time, but EU and UK individuals retain the right to object to this processing by contacting dpo@checkout.com.

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.
  • Delete Your Data
    Email dpo@checkout.com to object to processing of your personal data on legitimate interests grounds, specifying the processing activity you object to and the grounds for your objection under GDPR Article 21.

How other platforms handle this

Square Medium

to object to profiling activities based on our own legitimate interests

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Skillshare Medium

When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We may process your personal data where it is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your interests or fundamental rights and freedoms. Legitimate interests include fraud prevention, network and information security, improving our services, and direct marketing to business contacts.

Excerpt from Checkout.com's Privacy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

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 →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
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
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-010387
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-010387
Captured: 2026-05-08 15:31:40 UTC
SHA-256: a644fb34e781c2f8…
URL: https://conductatlas.com/platform/checkoutcom/checkoutcom-privacy/provision/CA-P-010387/legitimate-interests-as-legal-basis/
Accessed: Sept. 26, 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

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Checkout.com's Legitimate Interests as Legal Basis clause do?

Legitimate interests is a flexible but contested legal basis under GDPR; individuals have the right to object to processing on this basis, and Checkout.com must stop unless it can demonstrate compelling grounds that override the individual's interests.

How does this clause affect you?

Processing on legitimate interests grounds means Checkout.com may use personal data for fraud prevention, analytics, and marketing to business contacts without asking for consent each time, but EU and UK individuals retain the right to object to this processing by contacting dpo@checkout.com.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 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.