Coinbase · Coinbase Privacy Policy

Cross-Border International Data Transfers

Medium severity
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What it is

Coinbase transfers your personal data to the United States and other countries that may have weaker privacy laws than your home country, relying primarily on Standard Contractual Clauses for EU users.

Change history

modified Apr 29, 2026

Current version adds explicit 'consent by using our Services' language and emphasizes data protection disparity, while removing specific mention of EEA, UK, and Switzerland.

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Consumer impact (what this means for users)

Your personal and financial data is transferred internationally to the United States and potentially other countries, which may provide fewer privacy protections than your home jurisdiction, affecting EU/EEA users' ability to enforce their GDPR rights.

Cross-platform context

See how other platforms handle Cross-Border International Data Transfers and similar clauses.

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Why it matters (compliance & risk perspective)

If you are in the EU/EEA, your data being transferred to the US means it may be subject to US government surveillance programs, and your GDPR rights may be harder to enforce against a US-based company.

View original clause language
By using our Services, you consent to the transfer of your personal information to countries outside of your country of residence, including to the United States, which may not provide the same level of data protection as your home country. We take steps to ensure that any international transfers of personal information are subject to appropriate safeguards, such as standard contractual clauses approved by the European Commission.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: GDPR Chapter V (Arts. 44-49) governs international transfers of personal data from the EEA; valid transfer mechanisms include adequacy decisions (EU-US Data Privacy Framework effective July 2023), Standard Contractual Clauses (SCCs — Commission Decision 2021/914), Binding Corporate Rules, and Art. 49 derogations. Schrems II (C-311/18) requires transfer impact assessments (TIAs) for SCCs. UK GDPR and the UK-US data bridge apply for UK users. Swiss Federal Act on Data Protection (nFADP) applies for Swiss users. GDPR Art. 49(1)(a) consent as a transfer basis requires explicit, informed consent and is permissible only for non-repetitive transfers — reliance on user consent in a ToS for routine transfers is unlikely to withstand DPA scrutiny. Enforcement authorities: EU/EEA national DPAs, EDPB, ICO (UK), and Swiss FDPIC.

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Applicable agencies

  • FTC
    FTC is the US enforcement authority for the EU-US Data Privacy Framework and can enforce compliance obligations for self-certified US companies including Coinbase under the DPF arbitration mechanism.
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Provision details

Document information
Document
Coinbase Privacy Policy
Entity
Coinbase
Document last updated
April 29, 2026
Tracking information
First tracked
April 28, 2026
Last verified
April 28, 2026
Record ID
CA-P-003942
Document ID
CA-D-00048
Evidence Provenance
Source URL
Wayback Machine
SHA-256
0df5ab0df20db0a78e8b5a6a0df5e76babd3c3ab052afbbf8fc888f9ea388099
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Coinbase | Document: Coinbase Privacy Policy | Record: CA-P-003942
Captured: 2026-04-28 09:19:28 UTC | SHA-256: 0df5ab0df20db0a7…
URL: https://conductatlas.com/platform/coinbase/coinbase-privacy-policy/cross-border-international-data-transfers/
Accessed: May 2, 2026
Classification
Severity
Medium
Categories

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