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
In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals...
We do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files, to target advertising to you.
We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.
"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 Privacy Policy
REGULATORY FRAMEWORK: This provision directly implicates GDPR Art.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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 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 279 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Cloudflare.