This provision establishes that personal data transferred from the EEA, UK, or Switzerland to third countries without an adequacy decision is conducted under Standard Contractual Clauses incorporated into the agreement, serving as the legal transfer mechanism.
This analysis describes what Google Ads'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
This clause provides the contractual basis for international data transfers required by Google Ads operations. Advertisers and their legal teams should evaluate whether the Standard Contractual Clauses referenced reflect the current European Commission SCCs adopted in 2021 and whether a transfer impact assessment has been conducted in accordance with EDPB guidance.
Interpretive note: The specific version of Standard Contractual Clauses referenced and the module selection are not confirmed from the document excerpt available; advertisers should verify these details in the full executed agreement.
Under this clause, personal data processed through Google Ads that originates in the EEA, UK, or Switzerland may be transferred internationally to Google infrastructure in third countries, with Standard Contractual Clauses serving as the stated legal basis for that transfer.
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"To the extent that the transfer of Customer Personal Data from the European Economic Area, the United Kingdom, or Switzerland to countries not providing an adequate level of data protection is required to fulfill Google's obligations under this Agreement, the parties agree that such transfers are made subject to the Standard Contractual Clauses incorporated herein.— Excerpt from Google Ads's Google Ads Data Processing Terms
1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (Articles 44-49) governing transfers to third countries, as well as the equivalent provisions of UK GDPR and the Swiss Federal Act on Data Protection. The European Commission's Standard Contractual Clauses adopted in June 2021 are the operative transfer mechanism. The CJEU's Schrems II judgment requires a transfer impact assessment supplementing SCCs where the destination country's surveillance laws may undermine the protection SCCs provide. Enforcement authority rests with EU supervisory authorities, the UK ICO, and the Swiss FDPIC. 2) GOVERNANCE EXPOSURE: High for EU and UK advertisers. Post-Schrems II, reliance on SCCs alone without a documented transfer impact assessment creates regulatory exposure. EU supervisory authorities have taken enforcement action against entities relying on SCCs without conducting adequate transfer impact assessments, particularly for transfers to the United States. 3) JURISDICTION FLAGS: EU/EEA and UK advertisers face the most direct exposure. Swiss advertisers must evaluate compliance under the revised Swiss Federal Act on Data Protection effective September 2023. Advertisers in these jurisdictions should confirm whether the version of SCCs referenced in the agreement has been updated to reflect the 2021 European Commission SCCs and whether UK-specific International Data Transfer Agreements have been executed where required. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm the specific version of SCCs incorporated by reference and evaluate whether the modules selected (controller-to-processor) are appropriate for the advertiser's relationship with Google. Transfer impact assessments documenting the legal and technical safeguards for transfers to Google infrastructure in the United States or other third countries should be prepared and maintained. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the transfer impact assessment process, identify the specific Google data center locations involved in processing, review Google's published information on government access requests and technical safeguards, and retain records of this evaluation as evidence of due diligence in response to potential supervisory authority inquiries.
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This clause provides the contractual basis for international data transfers required by Google Ads operations. Advertisers and their legal teams should evaluate whether the Standard Contractual Clauses referenced reflect the current European Commission SCCs adopted in 2021 and whether a transfer impact assessment has been conducted in accordance with EDPB guidance.
Under this clause, personal data processed through Google Ads that originates in the EEA, UK, or Switzerland may be transferred internationally to Google infrastructure in third countries, with Standard Contractual Clauses serving as the stated legal basis for that transfer.
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