Provision record
Grammarly · Grammarly Privacy Policy · View original document ↗

Data Transfers and International Processing

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Document Record

What it is

The policy states that personal data may be transferred and processed outside the user's country of residence, and that the company applies the protections described in the policy and complies with applicable legal transfer frameworks including standard contractual clauses for non-DPF transfers.

This analysis describes what Grammarly'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)

This provision establishes the legal transfer mechanisms Superhuman relies upon for international data flows, including the Data Privacy Frameworks for EEA, UK, and Swiss transfers and standard contractual clauses for transfers to other third countries.

Recent Activity

This document changed recently

Medium Jul 7, 2026

The updated policy now discloses that Grammarly collects voice data if you use transcription or Notetaker features, including recordings of other participants, and expands its list of collected content to explicitly include screen content and web pages. For users whose accounts are managed by an organization (employer, school, or other entity), the policy clarifies that Grammarly's privacy terms do not apply to the content you upload or output—your organization's privacy terms govern that data instead. This means organizational account users should review their organization's privacy policies rather than relying on Grammarly's policy to understand how their work or educational data is handled.

View change record →

Consumer impact (what this means for users)

Under this provision, user data including account information, user content, and technical data may be transferred to and processed in the United States and potentially other countries. For EEA, UK, and Swiss users, the Data Privacy Framework certification and standard contractual clauses are identified as the applicable transfer safeguards.

Cross-platform context

See how other platforms handle Data Transfers and International Processing and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
We may transfer and process your data outside of the country where you live. Countries' data protection laws vary, with some providing more protection than others. Regardless of where your information is processed, we apply the protections described in this policy and we comply with certain legal frameworks relating to the transfer of data, including ensuring that relevant safeguards are in place for the transfer of data where required by law.

Excerpt from Grammarly's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V requirements for lawful transfers of personal data to third countries, including the EU-U.S.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Grammarly Privacy Policy
Entity
Grammarly
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015879
Document ID
CA-D-00456
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
7c74cfd243c4d415033b559955787624b7005dd4395d828c2e66590e2225ee5f
Analysis generated
July 9, 2026 09:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Grammarly
Document: Grammarly Privacy Policy
Record ID: CA-P-015879
Captured: 2026-07-09 09:01:20 UTC
SHA-256: 7c74cfd243c4d415…
URL: https://conductatlas.com/platform/grammarly/grammarly-privacy-policy/provision/CA-P-015879/data-transfers-and-international-processing/
Accessed: Sept. 15, 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 Grammarly's Data Transfers and International Processing clause do?

This provision establishes the legal transfer mechanisms Superhuman relies upon for international data flows, including the Data Privacy Frameworks for EEA, UK, and Swiss transfers and standard contractual clauses for transfers to other third countries.

How does this clause affect you?

Under this provision, user data including account information, user content, and technical data may be transferred to and processed in the United States and potentially other countries. For EEA, UK, and Swiss users, the Data Privacy Framework certification and standard contractual clauses are identified as the applicable transfer safeguards.

Is ConductAtlas affiliated with Grammarly?

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