The policy discloses that user data may be transferred to and processed in countries other than the user's country of residence, which may have different data protection standards.
This analysis describes what Ideogram'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 that personal data may be transferred internationally, including to jurisdictions with different data protection frameworks. The policy does not specify the transfer mechanisms used to legitimize transfers from the EU or UK, such as Standard Contractual Clauses or adequacy decisions, which is a material disclosure gap for GDPR compliance.
Interpretive note: The policy does not identify the specific legal mechanisms used to legitimize cross-border transfers from EU or UK jurisdictions, leaving the adequacy of transfer safeguards uncertain from the policy text alone.
The updated policy now provides explicit disclosure of which categories of personal information are collected and which parties receive each category. Previously, the policy required readers to consult other sections to identify this information. The updated table format discloses that identifiers such as name and email address, visual information including uploaded images, and geolocation data may be shared with other users, vendors, service providers, login integration partners, social media widgets, and affiliates. This change provides clearer visibility into data sharing practices without altering what data is collected or shared, but rather how that information is disclosed.
View change record →The updated policy no longer provides a single consolidated view of which specific categories of recipients receive which types of personal data. Previously, users could see in one table that identifiers, commercial information, geolocation data, images, account credentials, and precise location were shared with specific recipient categories such as vendors, service providers, other users, login partners, social media widgets, and tracking technology providers. The revised policy instead directs users to review other sections of the document to find this information. The specificity and accessibility of this disclosure has been reduced, though the underlying data-sharing practices may remain unchanged.
View change record →Under this provision, personal information submitted to Ideogram may be transferred to and processed in countries outside the user's country of residence, potentially including jurisdictions with differing data protection standards. The policy does not identify the specific transfer safeguards applicable to cross-border transfers from EU or UK jurisdictions.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Your information may be stored, transferred to and processed outside of your country of residence, including transferred to recipients in other countries which may have data privacy or protection rules that are different from your country of residence or citizenship.Excerpt from Ideogram's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR Chapter V governing international data transfers, which requires that transfers to third countries be subject to an adequacy decision, Standard Contractual Clauses (SCCs), Binding Corporate Rules, or another …
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This provision establishes that personal data may be transferred internationally, including to jurisdictions with different data protection frameworks. The policy does not specify the transfer mechanisms used to legitimize transfers from the EU or UK, such as Standard Contractual Clauses or adequacy decisions, which is a material disclosure gap for GDPR compliance.
Under this provision, personal information submitted to Ideogram may be transferred to and processed in countries outside the user's country of residence, potentially including jurisdictions with differing data protection standards. The policy does not identify the specific transfer safeguards applicable to cross-border transfers from EU or UK jurisdictions.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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