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

Dual Controller and Processor Role Distinction

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Document Record

What it is

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

The notice establishes that Checkout acts as a data controller for its own processing activities but may act as a data processor for Merchant Customer data when processing on a Merchant's behalf, directing affected individuals to the Merchant's own privacy notice in processor contexts.

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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)

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

This provision establishes that the accountability and transparency obligations for Merchant Customer data may rest with the Merchant rather than Checkout in certain processing contexts, which has direct implications for where affected individuals must direct data rights requests and complaints.

Recent Activity

This document changed recently

Medium Jul 8, 2026

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.

View change record →

Consumer impact (what this means for users)

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

Under these terms, when Checkout processes consumer data on behalf of a Merchant, the Merchant is the data controller and Checkout is the data processor, meaning that data rights requests and privacy complaints in those contexts should be directed to the Merchant rather than to Checkout. The notice directs consumers to consult the Merchant's privacy notice to understand how that data is processed.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
This notice applies where Checkout act as a data controller, but we may sometimes operate as a data processor for Merchant Customer data where we carry out instructions and process data on a Merchant's behalf. In these instances, you should refer to the privacy notice of the Merchant for details regarding how they process your information.

Excerpt from Checkout.com's Privacy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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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 →

Provision details

Document information
Document
Checkout.com Privacy
Entity
Checkout.com
Tracking information
First captured by ConductAtlas
May 5, 2026
Text quoted from version
CA-V-007201, captured Sept. 29, 2026
Record ID
CA-P-016117
Document ID
CA-D-000663
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007201)
ea0090cf400b3b347f0f5bbd6446b38bee256baa3327fad4f9061e1606a6f402
Analysis generated
July 9, 2026 09:37 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-007201, captured Sept. 29, 2026 (checked Oct. 5, 2026)
Citation Record
Entity: Checkout.com
Document: Checkout.com Privacy
Record ID: CA-P-016117
Version: CA-V-007201
Captured: 2026-09-29 01:14:49 UTC
SHA-256: ea0090cf400b3b34…
URL: https://conductatlas.com/platform/checkoutcom/checkoutcom-privacy/provision/CA-P-016117/dual-controller-and-processor-role-distinction/
Accessed: Nov. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

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Frequently Asked Questions

What does Checkout.com's Dual Controller and Processor Role Distinction clause do?

This provision establishes that the accountability and transparency obligations for Merchant Customer data may rest with the Merchant rather than Checkout in certain processing contexts, which has direct implications for where affected individuals must direct data rights requests and complaints.

How does this clause affect you?

Under these terms, when Checkout processes consumer data on behalf of a Merchant, the Merchant is the data controller and Checkout is the data processor, meaning that data rights requests and privacy complaints in those contexts should be directed to the Merchant rather than to Checkout. The notice directs consumers to consult the Merchant's privacy notice to understand how that …

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.