The notice discloses that automated systems may process Merchant Customer data to make fraud detection decisions (potentially declining transactions) and identity verification decisions (potentially delaying or denying product or service access), with affected individuals in certain jurisdictions having the right to request human review of those decisions.
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
This provision establishes that automated processing may directly affect a consumer's ability to complete a transaction or access a service, and the right to request human review is stated to be jurisdiction-dependent, meaning not all affected individuals have the same recourse.
Interpretive note: The right to request human review is stated as jurisdiction-dependent and the notice does not specify which jurisdictions trigger that right, creating ambiguity for users outside the EU, UK, California, and Colorado.
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 →Under these terms, transactions initiated through Merchants using Checkout's fraud detection services may be declined by automated systems without prior human review, and identity verification outcomes may delay or deny access to products or services. The agreement states that individuals in certain jurisdictions may request human intervention in automated decisions by contacting dpo@checkout.com.
Cross-platform context
See how other platforms handle Automated Decision-Making for Fraud and Identity Verification and similar clauses.
Compare across platforms →"In the course of providing our services, we may make decisions using your personal data which are partially or wholly automated to help make our decisions and services secure and efficient. We use automated decision-making in the following circumstances: -Fraud detection: Where you are a Merchant Customer and you initiate a transaction with a Merchant that uses our fraud detection services, your information may be processed by Checkout for the purposes of fraud detection and prevention. In some cases, this may lead to an automated decision for a transaction to be declined or for further information to be requested from you in order to proceed. -Identity verification: Where you are a Merchant Representative or Merchant Customer and we ask you to provide identity information to sign up to one of our services, or you use our identity verification product, the information you provide may be subject to partially or wholly automated decisions as to whether we are able to verify your identity. In the event we are unable to effectively verify your identity, this could have the impact of delaying or denying you access to a product or service operated by Checkout or one of our Merchants.Excerpt from Checkout.com's Privacy
1.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
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.
This provision establishes that automated processing may directly affect a consumer's ability to complete a transaction or access a service, and the right to request human review is stated to be jurisdiction-dependent, meaning not all affected individuals have the same recourse.
Under these terms, transactions initiated through Merchants using Checkout's fraud detection services may be declined by automated systems without prior human review, and identity verification outcomes may delay or deny access to products or services. The agreement states that individuals in certain jurisdictions may request human intervention in automated decisions by contacting dpo@checkout.com.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Checkout.com.