This analysis describes what Duo Security'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 allocation of data controller responsibility clarifies the operational relationship and regulatory obligations between Cisco, the enterprise customer, and end users under data protection frameworks. It establishes that privacy right requests and data governance determinations flow through the enterprise customer as the primary data controller rather than through Cisco.
End users of Duo services deployed by enterprises must direct privacy requests to their employer or organization (the Duo customer) rather than to Cisco directly. The terms structure Cisco's liability and obligations around the enterprise customer's data controller status rather than direct relationships with individual users.
How other platforms handle this
When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...
If you are in the 'Designated Countries', LinkedIn Ireland Unlimited Company ('LinkedIn Ireland') will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services. If you are outside of the Designated Countries, LinkedIn Corporation will ...
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...
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"When Cisco acts as a data processor on behalf of our customers (e.g., when a business uses Duo to authenticate their employees), the customer is the data controller and is responsible for determining how and why personal data is processed. In these cases, individuals should contact the business (our customer) directly to exercise their privacy rights.— Excerpt from Duo Security's Duo Privacy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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This allocation of data controller responsibility clarifies the operational relationship and regulatory obligations between Cisco, the enterprise customer, and end users under data protection frameworks. It establishes that privacy right requests and data governance determinations flow through the enterprise customer as the primary data controller rather than through Cisco.
End users of Duo services deployed by enterprises must direct privacy requests to their employer or organization (the Duo customer) rather than to Cisco directly. The terms structure Cisco's liability and obligations around the enterprise customer's data controller status rather than direct relationships with individual users.
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