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
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.
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, 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.
Compare across platforms →"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
1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V requirements for lawful transfers of personal data to third countries, including the EU-U.S.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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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.
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.
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