Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The policy states that Superhuman is certified under the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Frameworks, and commits to resolving cross-border data transfer complaints first directly, then through VeraSafe as an alternative dispute resolution provider, with binding arbitration available as a final recourse under the Framework.
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
This provision establishes the operational dispute resolution pathway for EEA, UK, and Swiss individuals whose personal data is transferred to the United States, including a binding arbitration option before a Data Privacy Framework Panel as a last resort mechanism, with FTC jurisdiction over overall Framework compliance.
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 →Under this provision, EEA, UK, and Swiss users who have concerns about how their personal data is handled after transfer to the United States can escalate complaints through Superhuman directly, then to VeraSafe for alternative dispute resolution, and ultimately to binding arbitration before a Data Privacy Framework Panel. The Federal Trade Commission has jurisdiction over Superhuman's compliance with the Frameworks.
Cross-platform context
See how other platforms handle Data Privacy Framework Compliance and Dispute Resolution and similar clauses.
Compare across platforms →Monitoring
Grammarly has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"In compliance with the Frameworks, we commit to resolve complaints about our processing of your personal data under the Frameworks. If you have questions about our compliance with Frameworks Principles, you should first contact us at: privacy@superhuman.com. Under the Frameworks, we commit to refer unresolved complaints concerning our handling of personal data received under the Frameworks to VeraSafe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit here for more information or to file a complaint. If your complaint is not resolved through these channels, under certain conditions, a binding arbitration option may be available before a Data Privacy Framework Panel.Excerpt from Grammarly's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates the EU-U.S. Data Privacy Framework (and its UK Extension and Swiss-U.S. counterpart), administered by the U.S. Department of Commerce and subject to FTC enforcement jurisdiction as explicitly acknowledged in the policy. The Framework replaced Privacy Shield following the Schrems II ruling and is the basis for lawful transfer of EEA, UK, and Swiss personal data to Superhuman's U.S. operations. The adequacy decision underlying the EU-U.S. DPF is subject to ongoing review by the European Commission. 2) GOVERNANCE EXPOSURE: Medium. Framework certification creates legally binding commitments enforceable by the FTC. Any material deviation from Framework Principles in data handling practices could expose Superhuman to FTC enforcement action. Organizations relying on Superhuman's Framework certification as a transfer mechanism should monitor the status of the Framework's adequacy decision. 3) JURISDICTION FLAGS: This mechanism applies specifically to EEA, UK, and Swiss individuals whose data is transferred to the United States. Standard contractual clauses are cited as the alternative transfer mechanism for transfers to other third countries, which organizations in those regions should separately assess. 4) CONTRACT AND VENDOR IMPLICATIONS: Superhuman states it remains responsible under the Onward Transfer Principle for personal data disclosed to third-party processors. Organizational clients should confirm that Superhuman's processor agreements with sub-processors are consistent with this commitment and that sub-processors are identified or assessable. 5) COMPLIANCE CONSIDERATIONS: Legal teams at organizations using Superhuman for EEA or UK data processing should verify current Framework certification status at dataprivacyframework.gov, confirm that VeraSafe dispute resolution terms are accessible to affected individuals, and assess whether the binding arbitration mechanism satisfies data subject rights expectations under applicable supervisory authority guidance.
This provision establishes the operational dispute resolution pathway for EEA, UK, and Swiss individuals whose personal data is transferred to the United States, including a binding arbitration option before a Data Privacy Framework Panel as a last resort mechanism, with FTC jurisdiction over overall Framework compliance.
Under this provision, EEA, UK, and Swiss users who have concerns about how their personal data is handled after transfer to the United States can escalate complaints through Superhuman directly, then to VeraSafe for alternative dispute resolution, and ultimately to binding arbitration before a Data Privacy Framework Panel. The Federal Trade Commission has jurisdiction over Superhuman's compliance with the Frameworks.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Grammarly.