Glean holds active DPF certification covering EU, UK, and Swiss data transfers and states that DPF Principles supersede conflicting provisions in this Privacy Statement. For onward transfers to third parties, Glean's liability is conditioned on its ability to demonstrate it was not party to events causing damages.
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
The onward transfer liability clause conditions Glean's DPF liability on a demonstration defense, which under DPF Annex I and applicable Principles may shift the burden of proof to Glean but has operational implications for how damages claims arising from third-party processor conduct are handled.
Interpretive note: The enforceability and long-term adequacy status of the EU-U.S. Data Privacy Framework is subject to ongoing review by EU institutions; the practical scope of onward transfer liability may depend on DPF Annex I interpretation and applicable enforcement context.
Under this clause, EEA, UK, and Swiss residents whose data is transferred to the U.S. are covered by DPF Principles, which supersede conflicting Privacy Statement terms; individuals may invoke binding arbitration for unresolved DPF complaints through the mechanism described in DPF Annex I.
Cross-platform context
See how other platforms handle EU-U.S. Data Privacy Framework Certification and Onward Transfer Liability and similar clauses.
Compare across platforms →"Glean has certified to the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework (DPF) Principles, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, and is committed to all relevant framework Principles. To the extent any conflict exists between this Privacy Statement and the applicable Data Privacy Framework Principles, the relevant Principles shall govern. Glean uses standard contractual clauses for onward transfers to third parties unless we can demonstrate we were not a party to the events giving rise to any damages.Excerpt from Glean's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly implicates the EU-U.S.
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The onward transfer liability clause conditions Glean's DPF liability on a demonstration defense, which under DPF Annex I and applicable Principles may shift the burden of proof to Glean but has operational implications for how damages claims arising from third-party processor conduct are handled.
Under this clause, EEA, UK, and Swiss residents whose data is transferred to the U.S. are covered by DPF Principles, which supersede conflicting Privacy Statement terms; individuals may invoke binding arbitration for unresolved DPF complaints through the mechanism described in DPF Annex I.
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