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Enterprise vs Consumer Data Processing Distinction

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

If you use Grammarly through your employer or an organization's business account, your data is governed by a separate contract and your employer's privacy policy, not this consumer policy.

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 creates a bifurcated regulatory framework where enterprise customers operate under distinct data processing terms negotiated between the customer and Grammarly, rather than under the standard consumer privacy policy. This allows differentiated data handling obligations based on customer classification.

Consumer impact (what this means for users)

Employees using Grammarly through a company or institutional account should check with their employer about what data protections apply, as the consumer privacy policy may not govern how their writing and usage data is handled in a business context.

How other platforms handle this

Adyen Medium

In providing the services, Adyen will process personal data in accordance with its Privacy Policy and applicable data protection laws, including the General Data Protection Regulation. You are responsible for ensuring that you have the necessary consents and legal bases to share personal data with A...

Smartsheet Medium

When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...

Dun & Bradstreet Medium

We process many types of data to support business decisioning, including data about people, businesses, organizations, places, economic activity, sustainability, legal, and other significant business events, and third-party risks. Some of the data we process is considered personal data. Some of the ...

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▸ View Original Clause Language DOCUMENT RECORD
"
When Grammarly processes information on behalf of a Grammarly Business customer, we do so pursuant to a separate data processing agreement with that customer, and the customer's privacy policy (not this Privacy Policy) applies to the personal data of that customer's users.

— Excerpt from Grammarly's Grammarly Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The enterprise data processing agreement framework engages GDPR Article 28 (processor obligations), CCPA/CPRA business-to-business exemptions, and FERPA for educational institution deployments. Grammarly's role as a data processor under enterprise agreements means the customer organization acts as controller and bears primary GDPR compliance responsibility. HIPAA business associate agreement requirements may apply if covered entities use Grammarly Business in contexts involving protected health information, though the policy does not address this scenario. GOVERNANCE EXPOSURE: Medium to High depending on sector. Organizations in regulated industries that deploy Grammarly Business without reviewing the data processing agreement for appropriate scope limitations, sub-processor lists, and breach notification provisions may have material compliance gaps. The explicit carve-out of AI training for Business users is a significant mitigation, but only if the DPA is reviewed and properly executed. JURISDICTION FLAGS: EEA enterprise deployments require a GDPR-compliant DPA under Article 28. US federal contractor or healthcare deployments may require additional contractual terms. Educational institutions must assess FERPA applicability. CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should treat the Grammarly Business DPA review as a mandatory due diligence step, not an optional add-on. Key provisions to assess include: data retention and deletion terms, sub-processor notification rights, audit rights, breach notification timelines, and explicit exclusion of user content from AI training pipelines. The consumer policy's AI training use should be verified as inapplicable to enterprise-context data. COMPLIANCE CONSIDERATIONS: Organizations deploying Grammarly Business should maintain a copy of the executed DPA, map what user data flows to Grammarly, and incorporate Grammarly into their vendor risk management framework. Employee privacy notices should reflect the organizational data processing context. Periodic DPA reviews should be triggered by updates to Grammarly's sub-processor list or material changes to the service.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Grammarly Privacy Policy
Entity
Grammarly
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 9, 2026
Record ID
CA-P-007156
Document ID
CA-D-00456
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d08a9713ff1dfd27ddd4383c3d20e95b0e83f623b74496507b64d9362c696444
Analysis generated
April 30, 2026 06:25 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Grammarly
Document: Grammarly Privacy Policy
Record ID: CA-P-007156
Captured: 2026-04-30 06:25:07 UTC
SHA-256: d08a9713ff1dfd27…
URL: https://conductatlas.com/platform/grammarly/grammarly-privacy-policy/enterprise-vs-consumer-data-processing-distinction/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Grammarly's Enterprise vs Consumer Data Processing Distinction clause do?

This provision creates a bifurcated regulatory framework where enterprise customers operate under distinct data processing terms negotiated between the customer and Grammarly, rather than under the standard consumer privacy policy. This allows differentiated data handling obligations based on customer classification.

How does this clause affect you?

Employees using Grammarly through a company or institutional account should check with their employer about what data protections apply, as the consumer privacy policy may not govern how their writing and usage data is handled in a business context.

Is ConductAtlas affiliated with Grammarly?

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