Garmin · Garmin Privacy Statement · View original document ↗

International Data Transfers via Standard Contractual Clauses

Medium severity High confidence Explicitdocumentlanguage Uncommon · 11 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Consumer impact (what this means for users)

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.

How other platforms handle this

Upwork Medium

When we transfer personal data outside the European Economic Area, United Kingdom, or Switzerland, we use appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your data is protected.

Unity Medium

Personal data collected by Unity may be transferred to and processed in countries outside of the European Economic Area, including the United States, where data protection laws may differ from those in your country. Where we transfer personal data from the EEA or the UK, we rely on appropriate safeg...

Bluesky Medium

We may transfer, process, and store all personal information we collect anywhere in the world. Different countries have different data protection laws. If we transfer personal information from the European Economic Area, Switzerland, Brazil and/or the United Kingdom to a country that does not provid...

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Garmin Privacy Statement
Entity
Garmin
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010356
Document ID
CA-D-00274
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3a2b2ed8f215b9045d68b47094629a426b4edde1ad52c9be6b8dcee1a05f474c
Analysis generated
May 8, 2026 15:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Garmin
Document: Garmin Privacy Statement
Record ID: CA-P-010356
Captured: 2026-05-08 15:11:48 UTC
SHA-256: 3a2b2ed8f215b904…
URL: https://conductatlas.com/platform/garmin/garmin-privacy-statement/international-data-transfers-via-standard-contractual-clauses/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Garmin's International Data Transfers via Standard Contractual Clauses clause do?

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.

How does this clause affect you?

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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 11 platforms. See the full comparison.

Is ConductAtlas affiliated with Garmin?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Garmin.