Your personal data may be sent to and processed in the United States or other countries that may have weaker privacy protections than where you live.
This analysis describes what Fly.io'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
If you are in the EU, UK, or another jurisdiction with strong data protection laws, transfers to the US require specific legal safeguards that must be in place for the transfer to be lawful.
Interpretive note: The specific transfer mechanisms currently in use by Fly.io are not enumerated in the available document text; practical compliance depends on documentation not visible in this policy alone.
EU and UK users' data may be transferred to the United States, which requires Fly.io to have implemented appropriate transfer mechanisms such as Standard Contractual Clauses to comply with GDPR.
How other platforms handle this
You will provide personal information directly to our website in the United States. We may also transfer personal information to our partners and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data prote...
Notion is based in the United States and the information we collect is governed by U.S. law. If you are accessing our Services from outside of the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States an...
Your personal information may be transferred to and processed in countries other than your country of residence, including Canada and the United States, where our servers are located and our central database is operated. These countries may have data protection laws that are different from those in ...
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"By using our services, you acknowledge that your information may be transferred to and processed in countries outside of your own, including the United States, which may have data protection laws that differ from those in your jurisdiction.— Excerpt from Fly.io's Fly.io Privacy Policy
REGULATORY LANDSCAPE: Cross-border transfers from the EU and UK to the US engage GDPR Chapter V and UK GDPR equivalent transfer restriction provisions. Following the invalidation of Privacy Shield and the adoption of the EU-US Data Privacy Framework, transfer mechanisms must be current and properly implemented. EU supervisory authorities have enforcement jurisdiction over inadequate transfer mechanisms. GOVERNANCE EXPOSURE: Medium. The policy acknowledges cross-border transfers but does not specify which transfer mechanisms are in place. Compliance teams cannot verify adequacy from the policy text alone and must request confirmation of current transfer documentation from Fly.io. JURISDICTION FLAGS: EU and EEA users and UK users face the highest exposure. Any organization subject to GDPR that uses Fly.io to process EU resident data must confirm that appropriate transfer safeguards are documented. Swiss data protection law may also be relevant for Swiss-based users. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should request and review Fly.io's current transfer mechanism documentation, including any Standard Contractual Clauses or Data Privacy Framework certifications. Transfer impact assessments may be required depending on the categories of data transferred. COMPLIANCE CONSIDERATIONS: Legal teams should conduct a transfer impact assessment if processing sensitive categories of data through Fly.io. Any gaps in transfer documentation should be remediated before or during onboarding. The policy's general acknowledgment of transfers is insufficient on its own to satisfy GDPR transparency requirements regarding the specific safeguards in place.
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If you are in the EU, UK, or another jurisdiction with strong data protection laws, transfers to the US require specific legal safeguards that must be in place for the transfer to be lawful.
EU and UK users' data may be transferred to the United States, which requires Fly.io to have implemented appropriate transfer mechanisms such as Standard Contractual Clauses to comply with GDPR.
ConductAtlas has identified this type of provision across 78 platforms. See the full comparison.
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