Cloudflare separates itself into two roles: when you use Cloudflare's own products directly, Cloudflare is responsible for your data; but when a website you visit uses Cloudflare behind the scenes, that website's owner is responsible, not Cloudflare.
This analysis describes what Cloudflare'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 distinction allocates legal and operational responsibility between Cloudflare and its customers under data protection frameworks. By defining Cloudflare as processor rather than controller, the provision clarifies that customers retain primary accountability for lawful processing, while Cloudflare's role is limited to executing processing activities per customer direction.
If your data is processed by Cloudflare on behalf of a business you use, that business — not Cloudflare — is legally responsible for it, meaning Cloudflare will redirect your privacy requests to them and may not act on your behalf directly.
How other platforms handle this
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...
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...
Mixpanel acts as a data processor on behalf of its customers (the controllers) when processing end user data through the Mixpanel analytics platform, and as a data controller with respect to data it collects about its own website visitors and account holders.
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"In this Privacy Policy, we use the terms 'Cloudflare customer' and 'customer' to refer to entities that access and use the Services under our Terms of Service and any applicable agreement that Cloudflare may have with such entities, and 'end users' to refer to those whose information Cloudflare processes on behalf of our customers. Cloudflare acts as a data processor for certain personal data, processing it only on behalf of our customers and in accordance with their instructions. For such data, the relevant Cloudflare customer is the data controller and is responsible for ensuring that such processing complies with applicable law.— Excerpt from Cloudflare's Cloudflare Privacy Policy
REGULATORY FRAMEWORK: This provision directly implicates GDPR Art. 4(7) (controller definition), Art. 4(8) (processor definition), Art. 28 (processor obligations including written DPA requirements), and Art. 82 (joint liability). Under CCPA, the analogous distinction between 'business' and 'service provider' is governed by §1798.140(ag) and §1798.100. The ICO and EU supervisory authorities, including the Irish DPC, hold enforcement authority over these classifications.
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This distinction allocates legal and operational responsibility between Cloudflare and its customers under data protection frameworks. By defining Cloudflare as processor rather than controller, the provision clarifies that customers retain primary accountability for lawful processing, while Cloudflare's role is limited to executing processing activities per customer direction.
If your data is processed by Cloudflare on behalf of a business you use, that business — not Cloudflare — is legally responsible for it, meaning Cloudflare will redirect your privacy requests to them and may not act on your behalf directly.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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