The agreement states that Google is not the processor of payment transactions conducted through Google Pay and does not control payment availability, refunds, chargebacks, or fund balances. The terms direct users to their card issuer or the relevant merchant for payment disputes.
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 provision limits Google's stated contractual responsibility for transaction outcomes, refunds, and chargebacks, and directs dispute resolution to card issuers and merchants. The enforceability of these limitations may depend on applicable consumer protection and payment services regulations in specific jurisdictions.
Interpretive note: The enforceability of Google's liability disclaimer may vary by jurisdiction; applicable payment services and consumer protection law may impose obligations on Google regardless of this contractual assertion.
Under this clause, payment disputes, refund requests, and chargeback matters are directed to the user's card issuer or the merchant, as the agreement states that transactions are between the user and the merchant rather than with Google. The practical effect depends on applicable consumer protection and payment services law in the user's jurisdiction.
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"While Google Pay enables you to store your Payment Instruments and transmit their information to merchants or transit providers, Google does not process Google Pay transactions with such Payment Instruments, and does not exercise control over: the availability or accuracy of payment cards, funds, payments, refunds, or chargebacks; the provisioning (or addition) of Payment Instruments to Google Pay, or addition of funds to Payment Instrument balances; or other commercial activity relating to your use of Google Pay. For any concerns relating to the foregoing, please contact your Payment Instrument's issuer. You acknowledge and agree that your transactions through Google Pay are transactions between you and the merchant and not with Google or any of its affiliates.— Excerpt from Google Ads's Google Ads Terms of Service
(1) REGULATORY LANDSCAPE: This provision may interact with PSD2 (EU Payment Services Directive 2) and national payment services regulations that define the liability of payment service providers. Consumer protection frameworks in EU member states and the UK may limit the enforceability of blanket liability disclaimers where Google's role in the transaction chain creates legal obligations. The European Banking Authority and national financial regulators may have oversight depending on how Google's role is classified under applicable payment services law. (2) GOVERNANCE EXPOSURE: Medium. The liability disclaimer is standard for digital wallet providers but may face challenge in jurisdictions that impose liability on payment facilitators or technical service providers involved in the transaction chain. The statement that Google 'does not process' transactions does not necessarily resolve Google's regulatory classification under all applicable payment services laws. (3) JURISDICTION FLAGS: EU and EEA users operating under PSD2 may have rights against payment service providers that these terms do not fully address. UK users are subject to the UK Payment Services Regulations. In Japan, specific e-money card provisions apply (Section 3(f)), and Japanese financial services law may impose obligations not addressed by the general liability disclaimer. (4) CONTRACT AND VENDOR IMPLICATIONS: Corporate card users should note Section 3(d), which states that use of eligible corporate cards binds the employer to these Terms. Procurement teams should assess whether this liability allocation is consistent with their organization's payment governance policies. (5) COMPLIANCE CONSIDERATIONS: Legal teams in EU/EEA jurisdictions should assess whether Google's stated role as a non-processor is consistent with its classification under PSD2 or national payment services law, as the regulatory classification may affect the liability framework that applies to transaction disputes. Where consumer protection law imposes non-waivable rights, these disclaimer terms may be unenforceable as to those rights.
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This provision limits Google's stated contractual responsibility for transaction outcomes, refunds, and chargebacks, and directs dispute resolution to card issuers and merchants. The enforceability of these limitations may depend on applicable consumer protection and payment services regulations in specific jurisdictions.
Under this clause, payment disputes, refund requests, and chargeback matters are directed to the user's card issuer or the merchant, as the agreement states that transactions are between the user and the merchant rather than with Google. The practical effect depends on applicable consumer protection and payment services law in the user's jurisdiction.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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