When Garmin moves your personal data from the EU or UK to countries without equivalent data protection laws, it uses Standard Contractual Clauses as a legal mechanism to authorize that transfer.
This analysis describes what Garmin'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
Standard Contractual Clauses are the primary mechanism used to legally authorize EU personal data transfers to countries like the U.S., and their validity has been subject to legal challenge; understanding this mechanism helps EU users know the basis on which their data leaves the EU.
Your personal data collected in the EU, EEA, UK, or Switzerland may be transferred to the United States or other countries under Standard Contractual Clauses, meaning Garmin has committed contractually to applying EU-equivalent protections to that data even when it is outside the EU.
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Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"When we transfer personal data from the European Economic Area, Switzerland, or the United Kingdom to other countries that have not been found to provide an adequate level of protection, we use Standard Contractual Clauses or other appropriate safeguards to protect your personal data.— Excerpt from Garmin's Garmin Privacy Statement
REGULATORY LANDSCAPE: Standard Contractual Clauses for international data transfers are governed by GDPR Chapter V. The European Commission issued updated Standard Contractual Clauses in June 2021, and prior versions were required to be replaced by December 27, 2022. The Schrems II decision (Data Protection Commissioner v. Facebook Ireland, CJEU 2020) established that SCCs alone may be insufficient where the destination country's surveillance laws prevent their effective implementation, requiring transfer impact assessments for high-risk destinations including the United States. The EU-U.S. Data Privacy Framework adopted in 2023 provides an alternative adequacy mechanism for transfers to certified U.S. organizations. GOVERNANCE EXPOSURE: Medium. Use of SCCs is standard practice and legally recognized, but ongoing compliance requires that SCCs be updated to the 2021 versions and that transfer impact assessments be completed and documented for transfers to the U.S. and other countries where surveillance risk is identified. Supervisory authority enforcement activity regarding SCCs and transfer impact assessments has increased across EU member states. JURISDICTION FLAGS: EU/EEA users are the primary affected population. Swiss transfers are governed by Switzerland's revised FDPA transfer rules. UK transfers are governed by UK GDPR and the UK's International Data Transfer Agreement mechanism. Transfers to countries without adequacy decisions require either SCCs or another Article 46 safeguard. CONTRACT AND VENDOR IMPLICATIONS: All contracts with subprocessors in non-adequate countries must include updated 2021 Standard Contractual Clauses or equivalent. Procurement teams should maintain a record of transfer impact assessments for each major subprocessor jurisdiction and review them periodically for changes in legal context. COMPLIANCE CONSIDERATIONS: Legal teams should confirm that all SCCs used by Garmin are the June 2021 European Commission versions, that transfer impact assessments have been conducted for transfers to the U.S. and other high-surveillance jurisdictions, and that supplementary measures have been implemented where assessments identify risk. Garmin's use of the EU-U.S. Data Privacy Framework should be verified if it certifies under that framework, as it would provide an alternative adequacy basis for U.S. transfers.
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Standard Contractual Clauses are the primary mechanism used to legally authorize EU personal data transfers to countries like the U.S., and their validity has been subject to legal challenge; understanding this mechanism helps EU users know the basis on which their data leaves the EU.
Your personal data collected in the EU, EEA, UK, or Switzerland may be transferred to the United States or other countries under Standard Contractual Clauses, meaning Garmin has committed contractually to applying EU-equivalent protections to that data even when it is outside the EU.
ConductAtlas has identified this type of provision across 11 platforms. See the full comparison.
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