Glean stores and processes data in the United States and other countries. For EU and UK users, Glean uses legal mechanisms called Standard Contractual Clauses to make those international transfers lawful.
This analysis describes what Glean'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
Cross-border data transfers are a key GDPR compliance obligation. If the transfer mechanisms are not properly implemented, data flows to the US could be challenged by regulators or privacy advocates.
Interpretive note: Exact verbatim transfer mechanism language could not be confirmed from the truncated document; characterization reflects standard disclosure for US-based enterprise SaaS vendors with EU customer bases.
If you are based in the EU or UK, your personal data may be transferred to the United States where Glean's infrastructure is located, and the legal protections in the US may differ from those in your home country.
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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.
Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers and partners operate. By using our Services, you acknowledge that your personal information may be transferred to countries outside your country of residence, in...
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"Glean operates globally and may transfer your personal data to countries outside your home country, including to the United States, where our servers and operations are located. When we transfer personal data from the European Economic Area, United Kingdom, or Switzerland, we use appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.— Excerpt from Glean's Glean Privacy Policy
(1) REGULATORY LANDSCAPE: GDPR Chapter V governs international transfers of personal data from the EEA. The EU-US Data Privacy Framework (DPF) provides an adequacy mechanism for qualifying US companies; alternatively, Standard Contractual Clauses (SCCs) updated in 2021 by the European Commission are the most common mechanism used by SaaS vendors. UK GDPR has parallel requirements under the UK International Data Transfer Agreement (IDTA). The relevant enforcement authorities are EU national data protection authorities and the UK ICO. (2) GOVERNANCE EXPOSURE: Medium. Use of SCCs is standard practice for US SaaS vendors serving EU customers. However, post-Schrems II, controllers must also conduct Transfer Impact Assessments (TIAs) to verify that SCCs provide effective protection given the legal environment of the destination country. Enterprise customers should confirm whether Glean has conducted and can provide documentation of TIAs for US data transfers. (3) JURISDICTION FLAGS: EU and UK customers face the highest exposure. Swiss customers require separate assessment under the revised Federal Act on Data Protection (nFADP). Enterprises in sectors handling special category data (health, financial) face heightened scrutiny for cross-border transfers. (4) CONTRACT AND VENDOR IMPLICATIONS: The DPA with Glean should incorporate the current EU SCCs (2021 version) with appropriate module selections based on the controller-processor relationship. UK customers need the IDTA or UK addendum to the EU SCCs. Enterprise customers should request Glean's transfer documentation and confirm DPF certification status if applicable. (5) COMPLIANCE CONSIDERATIONS: Enterprises should include Glean in their cross-border transfer mapping and ensure the DPA documentation is current. Transfer Impact Assessments for US data transfers should be documented. Any change in Glean's data hosting regions should trigger a DPA review.
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Cross-border data transfers are a key GDPR compliance obligation. If the transfer mechanisms are not properly implemented, data flows to the US could be challenged by regulators or privacy advocates.
If you are based in the EU or UK, your personal data may be transferred to the United States where Glean's infrastructure is located, and the legal protections in the US may differ from those in your home country.
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